FOIA Production US Department of Education On PSLF - Pt. 2

OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
SECTION7: WHERETO SENDTHE COMPLETEDFORM

Return the completed form and any documentation to: If you need help completing this form, call:
(If no address is shown, return to your loan holder.) (If no telephone number is shown, call your loan holder.)
U.S.Department of Education Domestic 855- 265-4038

Fedloan Servicing Or Fax to: 717-7 20-1628 International: 717-720-1985
P.O.Box69184 TTY:dial 711. then enter 800-699- 2908
Harmburg, PA 17106-9184
Website. ~yf"cJL0Jr1.0ry
SECTION8: IMPORTANT INFORMATION ABOUT PSLF

You may obtain loan forgiveness under this program if you The Department will consider the lump sum payment
make 120 qualifying payments (see "Payment Eligibility'") on you have made as the equivalent of qualifying payments
eligible loans {see ··Loan Eligibility'") while working in equal to the lesser of (1) the number of payments resulting
qualifying employment {see ""Employment Eligibility"}. after dividing the amount of the lump sum payment by the
Payment Eligibility monthly payment amount you would have made under one
of the qualifying repayment plans listed below: or (2) 12
To receive PSLF,you must make 120 on-time, full,
payments.
scheduled, separate monthly payments on your Direct Loans
under a qualifying repayment plan after October 1, 2007. Peace Corps volunteers making an eligible lump sum
payment must do so within 6 months oft he Employment
On-time payments are those that are received by the
End Date, as reported in Section 3.
Department no later than 15 days after the scheduled
payment due date. Your payments must be made under a qualifying
repayment plan. Qualifying repayment plans include the
Full payments are payments on your Direct Loan in an
REPAYEplan, the PAYE plan, the IBR plan, the ICR plan, the
amount that equals or exceeds the amount you are required
10-Year Standard Repayment plan, or any other Direct Loan
to pay each month under your repayment schedule. If you
repayment plan, but only payments that are at least equal to
make a payment that is less than what you are required to
the monthly payment amount that would be required under
pay for that month, that month's payment will not count as
the 10-Year Standard Repayment plan.
one of the required 120 qualifying payments. If you make
multiple. partial payments in a month and the total of those Though repayment plans other than the REPAYE,PAYE,
partial payments equals or exceeds the required full IBR,and ICR plans are qualifying repayment plans for PSLF,
monthly payment amount, those payments will count as you must enter REPAYE,PAYE, IBR,or ICRto have a
one qualifying payment. remaining balance to forgive after becoming eligible for
PSLF.Otherwise, your loans will be fully repaid within 1O
Scheduled payments are those that are made while you
years. To apply for these plans, visit <,tuck-ntl 0.1n, gov.
are in repayment. They do not include payments made while
your loans are in an in-school or grace status, or in a IMPORTANT:The Standard Repayment Plan for Direct
deferment or forbearance period. Consolidation Loans made on or after July 1, 2006 have
repayment periods of different lengths. Monthly payments
You must make separate monthly payments. Lump sum
you make under the Standard Repayment Plan on such
payments or payments you make as advance payments for
Direct Consolidation Loans are only qualifying payments if
future months do not count as more than one qualifying
the loans have a 10-year repayment period (which would
payment. If you wish to make a payment in excess of your
only occur if your total education indebtedness is less than
scheduled monthly payment. follow the instructions on your
$7,500).
bill for providing payment instructions, and notate that your
payment 1snot intended to cover future installments. Loan Eligibility
Otherwise, your excess payment may affect your ability to
Only Direct Loan Program loans that are not in default
make future qua Iifying payments.
are eligible for PSLF.Loans you received under the Federal
If you were an AmeriCorps or Peace Corps volunteer, you Family Education Loan {FFEL) Program, the Federal Perkins
may receive credit for making qualifying payments if you Loan {Perkins Loan} Program, or any other student loan
make a lump sum payment by using all or part of a Segal program are not eligible for PSLF.
Education Award or Peace Corps transition payment.
Page 4 of 6
PHe.aa Employment Certification Review Manual

Proprietary & Conf1d!"nlial Page I 30
SECTION 8: IMPORTANT INFORMATION ABOUT PSLF (CONTINUED)

Loan Eligibility {Continued} Employment Eligibility [Continued)
If you have FFELProgram or Perkins Loan Program loans, You must be employed full-time by your employer.
you may consolidate them into a Direct Consolidation Loan
Generally, you must meet your employer's definition of
to take advantage of PSLF.However, payments made on
full-time. However, for PSLFpurposes, that definition must
your FFELProgram or Perkins Loan Program loans before
be at least an annual average of 30 hours per week. For
you consolidated them, even if they were made under a
purposes of the full-time requirement your qualifying
qualifying repayment plan, do not count as qualifying PSLF
employment at a 501 (c)(3) organization or a not-for-profit
payments. In addition, if you made qualifying payments on a
organization does not include time spent participating in
Direct Loan and then consolidate it into a Direct
religious instruction, worship services, or any form of
Consolidation Loan, you must start over making qualifying
proselyt1z1ng.
payments on the new Direct Consolidation Loan.
If you are a teacher, or other employee of a public service
If you consolidate your FFELProgram or Perkins Loan
organization, under contract for at least eight out of 12
Program loans into a Direct Consolidation Loan to take
months, you meet the full-time standard 1fyou work an
advantage of PSLFand do not have any Direct Loans, do not
average of at least 30 hours per week during the contractual
submit this form until you have consolidated your loans. The
period and receive credit by your employer for a full year's
on line application for Direct Consolidation Loans contains a
worth of employment.
section that allows you to indicate that you are
consolidating your loans for PSLF.The onl1ne application is If you are employed in more than one qualifying part-
available at ':ituden'.loans.gov. If you don"t know whether time job simultaneously, you may meet the full-time
you have Direct Loans, go to Stude11lAid.govilog111. employment requirement if you work a combined average
of at least 30 hours per week with your employers.
Employment Eligibility
Vacation or leave time provided by the employer or leave
To qualify for PSLF,you must be an employee of a taken for a condition that is a qualifying reason for leave
qualifying organization. An employee Is someone who is under the Family and Medical Leave Act of 1993, 29, U.S.C.
hired and paid by the organization. You may physically 2612(a)(l) and (3) is equivalent to hours worked in qualifying
perform your work at a qualifying or non-qualifying employment.
organization. so long as your employer is a qualifying
Other Important Information
organization. If you are a contracted employee, the
organization that hired and pays you must qualify, not the The submission of this form before you apply for PSLFis
organization where you perform your work. The type or optional However, if you wait to submit this form until you
nature of employment with the organization does not apply for PSLF,you will be required to submit one form for
matter for PSLFpurposes. each employer that you want considered toward your
eligibility for PSLF.
A qualifying organization is a government organization
or a tax-exempt organization under Section 501 {c)(3) of the If you submit this form and your employer qualifies, all of
Internal Revenue Code {IRC).Service In an Amer1Corps or your loans held by the Department will be transferred to
Peace Corps position is also qualifying employment. The FedLoan Servicing. Fedloan Servicing will then determine
type of services that these organizations provide does not how many qualifying payments you made during the period
matter for PSLFpurposes. of qualifying employment within the dates provided in
Section 3.
A private not-for-profit organization that is not a tax-
exempt organization under Section 501 (c)(3) of the IRC may You are not permitted to apply the same period of
be a qualifying organization 1fIt provides certain specified service to receive PSLFand the Teacher Loan Forgiveness,
public services. These services include emergency Service in Areas of National Need, and Civil Legal Assistance
management, military service, public safety, or law Attorney Student Loan Repayment programs.
enforcement services; public health services; public No borrower will be eligible for PSLFuntil October 2017
education or public library services; school library and other at the earliest. An application for PSLFwill be made available
school-based services; public interest law services: early at a later time.
childhood education; public service for individuals with
disabilities and the elderly. The organization must not be a
business organized for profit, a labor union, or a partisan
political organization.
Employment as a member of the U.S.Congress is not
qualifying employment.
Page~ of 6
PHeaa Employment Certification Review Manual

Proprietary & Conf,d!"ntial Page I 31
SECTION 9: IMPORTANT NOTICES

Privacy Act Notice. The Privacy Act of 1974 (5 U.5.C To assist program administrators with tracking
552a) requires that the following notice be provided to you: refunds and cancellations, disclosures may be made to
The authorities for collecting the requested guaranty agencies, to financial and educational instItutIons,
information from and about you are §421 et seq., §451 et or to federal or state agencies. To provide a standardized
seq., or §461 of the Higher Education Act of 1965, as method for educational institutions to efficiently submit
amended (20 U.5.C. 1071 et seq., 20 U.S.C.1087a et seq., or student enrollment statuses, disclosures may be made to
20 U.S.C.1087aa et seq.} and the authorities for collecting guaranty agencies or to financial and educational
and using your Social Security Number (SSNJare §§428B(f} institutions. To counsel you in repayment efforts, disclosures
and 484(a)(4J of the HEA {20 U.S.C.1078-2(1)and 1091(a)(4J) may be made to guaranty agencies, to financial and
and 31 U.5.C 7701 (bl. Participating in the William D. Ford educational institutions, or to federa I, state, or local
Federal Direct Loan {Direct Loan) Program, Federal Family agencies.
Education Loan {FFEL)Program, or Federal Perkins Loan In the event of litigation, we may send records to the
(Perkins Loan) Program and giving us your SSNare Department of Justice. a court, adjudicative body, counsel,
voluntary, but you must provide the requested information, party, or witness 1fthe disclosure is relevant and necessary
including your SSN,to participate. to the litigation. If this information, either alone or with
The principal purposes for collecting the other information, indicates a potential violation of law, we
information on this form, including your SSN,are to verify may send It to the appropriate authority for action. We may
your identity, to determine your eligibility to receive a loan send information to members of Congress if you ask them
or a benefit on a loan (such as a deferment, forbearance, to help you with federal student aid questions. In
discharge, or forgiveness) under the Direct Loan, FFEL,or circumstances involving employment complaints,
Federal Perkins Loan Programs, to permit the servicing of grievances, or disciplinary actions, we may disclose relevant
your loans, and, if it becomes necessary, to locate you and records to adjudicate or investigate the issues. If provided
to collect and report on your loans if your loans become for by a collective bargaining agreement, we may disclose
delinquent or default. We also use your SSNas an account records to a labor organization recognized under 5 U.S.C.
identifier and to permit you to access your account Chapter 71. Disclosures may be made to our contractors for
information electronically. the purpose of performing any programmatic function that
requires disclosure of records. Before making any such
The information in your file may be disclosed, on a
disclosure, we will require the contractor to maintain Privacy
case-by-case basis or under a computer matching program,
Act safeguards. Disclosures may also be made to qualified
to third parties as authorized under routine uses in the
researchers under Privacy Act safeguards.
appropriate systems of records notices. The routine uses of
Paperwork Reduction Notice. According to the
this information include, but are not limited to, its disclosure Paperwork Reduction Act of 1995, no persons are required
to federal, state, or local agencies, to private parties such as
to respond to a collection of information unless such
relatives, present and former employers, business and
collection displays a valid 0MB control number. The valid
personal associates, to consumer reporting agencies, to
0MB control number for this information collection is
financial and educational institutions, and to guaranty 1845-0110. Public reporting burden for this collection of
agencies in order to verify your identity, to determine your
information is estimated to average 30 minutes per
eligibility to receive a loan or a benefit on a loan, to permit
response, including time for reviewing instructions,
the servicing or collection of your loans, to enforce the searching existing data sources, gathering and maintaining
terms of the loans, to investigate possible fraud and to verify
the data needed, and completing and reviewing the
compliance with federal student financial aid program
collection of information. The obligation to respond to this
regulations, or to locate you if you become delinquent in collection is required to obtain a benefit in accordance with
your loan payments or if you default. To provide default rate
34 CFR685.219. If you have comments or concerns
calculations, disclosures may be made to guaranty agencies,
regarding the status of your individual submission of this
to financial and educational institutions, or to state
form. please contact your loan holder directly (see Section
agencies. To provide financial aid history information, 7).
disclosures may be made to educational instItutIons.
Page6of6
Employment Certification Review Manual

Proprietary & Conf1d!"17.lial Page I 32
Resources/Authority
34 CFR 685.219

Fedloan ServicingProcessorUpdate - PSECF ProcessingUpdate

CS Operational Communications Autum L Hosler 07/06/2017 12:45 PM
Autum L Hosler
From CS Operational Communications/Fedloan Servicing

To PSLF ECF Processors@PHEAA
Cc. Operational Communications & Procedures, CS Operational Communications/Fedloan
Servicing@PHEAA, Compliance/AES@pheaa
Date 11/05/201504:34 PM
SubJect· Fedloan Servicing Processor Update - PSECF Processing Update
Sent by Katherine Brubaker
Effective immediately, if an ECF is received for an American Civil Liberties Union

organization (e.g. ACLU Foundation, American Civil Liberties Union Fund, ACLU of VT,
etc.) the employer must be placed into the employer database for review by our
Compliance department.
CS Operational Communications
PSECF for EIN 20-8091013 - 11.08.2016

When reviewing an Employer Certification Form (ECF), if the Employer Identification
Number (EIN} is 20-8091013:
DO: Place the ECF on hold and submit the employer to the database.
DO NOT: Approve or deny the ECF without proper guidance from the database for that
individual borrower.
The employers associated with EIN 20-8091013 are:

• Center for Excellence in Higher Education (CEHE)
• Independence University
• Steven-Henager College
• CollegeAmerica
• California College San Diego
• California Flight Academy, or
• TTY (Training to You) Career College
For additional PSECF questions, please refer to the Public Service Loan Forgiveness
Employment Certification Processing Procedures in Knowledge Base.
PSLF ECFProcessor Reminder (Resource Updates 10.14.16)

Per procedures, processors MUST check the Public Service Loan Forgiveness (PSLF)
database located in Launch Pad prior to checking any other resources.
If the employer is located in the database:

• Check the date to ensure the employer has been approved within the past 12
months.
o If the employer was approved more than 12 months ago populate the PSNPR
Action Request Code (ARC).
If the employer is not located in the database:

• Utilize other resources
o Federal, State, local or Tribal government organization, agency, or entities
o Public schools, universities, and school districts, libraries
o Non-profit 501 (c)(3) organizations
o IRS Business Master File
For more information on this process, please refer to the Public Service Loan
Forgiveness Employment Certification Processing Procedures available in Knowledge
Base !Connect.
Please see a lead or supervisor with any questions.
PSLF Reminders - 11.03.2015

The Public Service Loan Forgiveness (PSLF) Program was established to encourage
individualsto enter and continueto work full-time in publicservice jobs. The program
allows eligible borrowers to apply for forgiveness on the remaining balance of their
Direct Loans, after serving full time at a public service organization for at least 1O years
while making 120 qualifying monthly payments after October 1, 2007.
Fed Loan Servicing is the sole servicer for the PSLF Program. Once a valid Employment
Certification Form (ECF) is received, verified, and approved, we will work with the
borrower's current servicer(s) to transer all of their federally-held loans to Fed Loan
Servicing. Information regarding the Program can be found on our website
www.MyFedLoan.org(Manage Account,Loan Forgivenessand Discharge Programs,
Public Service Loan Forgiveness).
The following resources are available on www.MyFedLoan.org/PSLF:
• Employment Certification Form (ECF)

• In order for us to determine if the borrower is employed by a qualifying public service
organization,we need to receive an ECF from the borrower.
• Borrowers should be encouraged to submit an ECF annually to determine if their
employment and their payments qualify for PSLF.
• Frequently Asked Questions
• Step-by-step instructions
Review the next tab for guidance on handling phone calls where the borrower inquires
about PSLF.
If you receive an incoming phone call from a borrower who wishes to know more, in
general, about PSLF (and the borrower is NOT requesting specific details concerning
PSLF as it relates to their account), please refer to the following basic information
regarding the program:
• The PSLF Program was established to encourage individuals to enter and continue
in full-time public service employment by forgiving the remaining balance of their
William D. Ford Direct Loan Program loans (Direct Loans) after the borrower has
made 120 separate, qualifying monthly payments (beginning any time after October
1, 2007) while employed full-time by a qualifying public service organization.
• Only Direct Loans can qualify for PSLF.
• The borrower MUST make payments under one of the following repayment plans to
have payments count towards PSLF:
• Income-Driven Repayment plans (IBR, ICR and PAYE)
• Note: IL, CO, and CP payments are still considered IDR payments. Therefore, these
are considered qualifying payments for PSLF.
• Standard Repayment plan (based on a repayment period of 120 months or less).
• Any other Direct Loan Program repayment plan with payments that are at least
equal to the monthly payment amount that would have been required under the
Standard Repayment Plan based on a 10-year repayment period.
• The payments do not have to be consecutive.
• Payments must be submitted timely during qualified periods of employment to count
towards PSLF. Payments must be received as follows:
I. No earlier than 30 days prior to the due date.
II. No later than 15 days after the due date.
Ill. Full, regularly scheduled installment amount must be received even if the
borrower is paid ahead and billed less than their monthly installment.
• Generally, lump sum payments will NOT count as more than one qualifying
payment. (There are exceptions for AmeriCorps or Peace Corps volunteers.)
If you receive an incomingphone call froma borrowerwho is reques,,.tiw,na,,_,,s~o~ec~iilfic~----
information concerning PSLF, you must COLD transfer the call to thf 1(5I
Examples include: ~-------~
• What loans should I consolidate for PSLF?
• What is the status of my ECF?
• How many of my payments qualify?
• I received a letter telling me I have XX payments that qualify, but I want to know why
the rest of my payments don't count?
• Why was my ECF denied?
• Does my employer qualify?
• When will my loans be transferred?
• When will I be notified of how many payments qualify?
For more information on PSLF, refer to the Public Service Loan Forgiveness (PSLF)
article on Knowledge Base.
There are a few common misconceptionswhen it comes to PublicService Loan

Forgiveness and advising borrowers. This is, in part, why we have dedicated staff to the
PSLF split to minimize erroneous guidance to borrowers interested in taking advantage
of this program. Still, some "bad information" has made its way to borrowers, and we
wish to provideguidance to eliminate such misinformation.Click on the Misconception
to find the Truth!
MISCONCEPTION: Borrowers should wait to submit an ECF confirming their

employment until the end of their 10-year employment period.
PSLF TRUTH: It is best for a borrower to submit an ECF early on in their career so we
can make sure they're on the right track, provide information on their repayment plan
options and keep them up-to-date on their progress towards forgiveness. NEVER
advise a borrowerto wait on submittingan ECF. Always encourage them to submit an

ECF annually, especially if they haven't submitted one within the last year.
MISCONCEPTION: Borrowers should consolidate all of their loans together to get the
most out of PSLF.
PSLF TRUTH: Because PSLF is available only on Direct Loans, borrowers may request
to consolidate those ineligible loans into a Direct Consolidation Loan. However,
consolidatingany existing Direct Loans into a new Direct Loan could cause a borrower
to lose potential qualifying payments toward forgiveness. They may wish to exclude any
Direct Loans in which they have already made qualifying payments from the new Direct
Consolidation Loan. Not all loans are eligible for consolidation. Click here for more
informationon Direct Loan ConsolidationOrigination(DLCO).
MISCONCEPTION: Satisfying the amount due on your monthly bill will make your
payment qualify for PSLF.
PSLF TRUTH: A borrower is required to make 120 separate on-time full monthly
payments after October 1, 2007. For the PSLF Program, a qualifying payment must
satisfy the full monthly payment due for that month. Even if a borrower has satisfied a
payment in advance (paid ahead status), they still need to make a full, regularly
scheduled monthly payment in order for it to count towards the required 120 qualifying
payments.
MISCONCEPTION: Employment as a congressional staffer does NOT qualify for PSLF.
PSLF TRUTH: Employment as an elected member of the U.S. Congress (Senator or

Representative) does NOT qualify for PSLF. However, employment as a congressional
staffer, working for a Senator or Representative, DOES qualify, as the staffers are
federal employees.
Exception: If a congressional staffer is working for a political campaign (considered a

partisan political organization), the staffer ceases to be a federal employee for that
specific time period. This means any payments made during the time that the staffer
was workingon election/re-electioneffortson behalf of the congressionalcandidate
would not qualify towards fulfilling the 120 qualifying monthly payments.
Top 3 PSLF Reminders (Resource Updates 06.14.17)

In order to provide great customer service, review the top 3 PSLF Reminders below. If
you have questions or need additional assistance, reach out to your lead or supervisor.
1. On PSLF Payment Tracker Letters
• You must complete all of the account checks outlined in the Direct Loans Only
When to: Submit the RVWPS ARC article in Knowledge Center (Content ID:
KM1004134), before submitting the RVWPS Action Request Code (ARC) for a
borrower to receive a PSLF payment tracker letter.
• Be sure to advise borrowers that these requests can take up to 90 days to process.
2. On Qualifying Loans
v'-
v'-
v'-
v'-
• If counseling a borrower for the first time about PSLF and their qualifying loans, be
sure to check NSLDS to determine if the borrower has eligible loans.
We should not ask the borrower what type of loans they have in order to determine
eligibility. Please take the time to use your resources and properly inform the borrower
of what actions they need/could take.
For more information, see the following articles in KC:

• Direct Loans Only: How to: Determine Eligibility for PSLF (Content ID:
KM1004111)
• Direct Loans Only: How to: Counsel a First Time Caller for PSLF (Content ID:
KM1004113)
•
3. On Employer Eligibility
• Always check the PSLF Organization Database before discussing the employer's
eligibility when counseling a borrower. We should not indicate that an employer is
'most likely' or 'approved' to participate in PSLF without checking the PSLF
Organization Database first.
• If you are unable to review the database, advise the borrower to complete an
Employment Certification Form (ECF) in order to determine the employer's eligibility.
See the Direct Loans Only How to: Determine if the Employer Qualifies (Content
ID: KM1004167) article in KC ..
SERVICING
Public Service Loan

Forgiveness
Employment
Certification
Processing Procedures
I
Customer Service
f SERVICING PSLFECFPROCESSING
PROCEDURES
Procedural Guide
Table of Contents
Table of Contents .................................................................................................... 1

Document Version Control ••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..• 3
Summary ..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..• 5
Acronyms .••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..• 5
Background .••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..• 6
Eligible Loans ........................................................................................................... 6
Qualifying Employment ............................................................................................. 6
Section 1: Employment Certification Form (ECF) Process ............................... 8
1.1 View Image ................................................................................................... 8
1.2 Review Demographics .................................................................................. 10
1.3 Review NSLDS............................................................................................. 12
1.4 No Eligible Loans Macro ............................................................................... 15
1.5 Review Document ........................................................................................ 19
1.6 Review Employer Website/Directory ............................................................. 33
1.7 ECF Under Review ....................................................................................... 46
1.8 Process/Update ECF Screen .......................................................................... 47
1.9 Sending A Manual Letter .............................................................................. 56
1.10 Process RVECF............................................................................................ 59
1.11 Commenting ................................................................................................ 60
1.12 Archive Image ............................................................................................. 63
Prerequisite Documents ••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••. 65
Related Documents ••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••. 65
Related Letters •..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••. 65
Related Technologies/Reports .••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••..••. 66
PSLF ECF Processing Procedures

Propnetary & Confidential
f SERVICING PSLFECFPROCESSING
PROCEDURES
Procedural Guide
Screens .................................................................................................................. 66
Work Queues/Action Request Codes (ARCs) ............................................................. 66
~~ ................................................................................................................... ~
PageCenter Reports ................................................................................................ 67
SAS Jobs ................................................................................................................ 67
Other ..................................................................................................................... 67
Appendix A - Frequently Asked Questions ........................................................ 68
Appendix B - Loan Abbreviations ....................................................................... 69
Appendix C - Digital Signatures .......................................................................... 69
Resources/Authority ............................................................................................. 70
PSLFECFProcessing Procedures
Propnetary & Confidential
Document Version Control

Version Purpose/Change Author/Reviewer Date
1.0 Existing BU 1/04/2013

2.0 Per BU and Compliance, key changes and additions made to 5. 11/17/2015
first draft. Examples: Qualifying Employment section: Info Dalbor/Compliance
added --serving Congress members not eligible but their
staffers are eligible
Section 1.2-0btaining contact information for the borrower
Section 1.2 and 1.5-Phone scripts for confirming
employment status
Section 1.3-Finding previous DOE loan servicers on a
borrower's account in NSLDS
Section 1.4-Using No Eligible Loans macro
Section 1.5-Documentation needed to determine if
borrower worked for a qualifying organization, and whether
organization is still operational
Section 1.6-ldentifying organizations on state websites that
are not government entities (e.g. nursing homes)
Section 1.8-How to handle multiple ECFsand ECFswith
various expiration dates (11/30/2014 vs 12/31/2017)
- Sending manual vs system denial letters
- Identifying four statuses (Approved, Denied,
Conditionally Approved, or Review) and sending
letters for each
Added FAQs
Published A. Dullebawn 11/17/2015
2.1 Fast Track update to Review Employer Website/Directory S. Dalbor 1/18/2016
Section that any ECFreceived for an ACLU organization must
be placed in the employer database for review by
Compliance. Per Incident 29045528511, PSLFProcessing-
ACLU.
2.2 Modifications to numbering/lettering in Section 1.8, S. Dalbor 3/03/2016

Process/Update ECFScreen, incorporated per Compliance
guidance. Reformatted per Style Guide.
2.3 Compliance approved version K. Myers 3/08/2016

Published by Communications A. Dullebawn 3/9/2016
Date All Changes for this Version are Effective for Staff A. Dullebawn 3/11/2016
f loan PSLF ECF Processing Procedures

OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND Proprietary
AMERICAN & Confidential
FEDERATION OF TEACHERS UNDER THE FREEDOM Page I3
OF INFORMATION ACT
2.4 Fast Track Updates: Per incident 29045583097, PSLF S. Dalbor 4/7/2016
Processing and Toolkit Updates (OPM Review), Updated the
following sections:
• Section: 1.8 Process/Update ECFScreen regarding how to
calculate the begin date for continuous employment on a
newly received ECF
• Added Section 1.9 Process RVECF Instructions for
processing and working the RVECF (PSLF REVIEW ECF) ARC
• Section 1.6: Review Employer Website/Directory
regarding Tribal Link Updates and adding detailed steps of
the process with screenshots
• Section 1.3 Review NSLDSby adding instruction on how to
deny a request due to No Eligible Loans
• Section 1.4 by adding instruction on No Eligible Loans
Macro How to notate for No Eligible Loans and adding
instruction for which indicators to update
• Section 1.7 ECFUnder Review by Adding steps for
completing request based on review in the database
Per incident 29045583050, CR 3583 PSECFRelease, Updated
the following sections:
• Section 1.5 Review Document, added info about new form
with no Box 15 and processors should counsel borrowers
to print out form from website and added steps for
requesting to override judgement of denied employer,
attached certification, escalated situations, and Self-
Certified Review from section 1.6: Review Employer
Website/Directory
• Section 1.6 - Review Employer Website/Directory-
Updated to show that PSLFOrganization Database has
being migrated into LauchPad. Added updated screen
shots.
• Section 1.8 - Process/Update ECFScreen - Added
instruction for a new ECFreceived that recertifies the
borrower's employment
• Added Section 1.9: Sending a Manual Letter
• Added Section 1.10: Process RVECF
FASTTRACKper incident 29045S83882: CR 3793 VSAC 8/9/2016
Decommission 8/15/16 updated Section 1.8: Process/Update T. Galloway
ECFScreen by removing VSACfrom table.
Compliance Approved K. Myers 8/1S/2016

Published by Communications V. Edwards 08/1S/2016
Date All Changes for this Version are Effective for Staff V. Edwards 08/19/2016

OF INFORMATION ACT
Summary
Fed loan Servicing (FLS) determines whether the borrower's employer qualifies for Public Service Loan
Forgiveness ( PSLF)when a borrower submits an Employment Certification Form (ECF). All of the borrower's
U.S. Department of Education-owned FFELPand Direct Loans that are not already serviced by FLSwill be
transferred to FLSif the employer qualifies and the borrower has at least one eligible Direct Loan. Having all
of the borrower's Department of Education-owned loans with the same servicer allows for more efficient
tracking of the borrower's progression in the PSLFProgram.
5
COMPASS M screen TL2U was created just for PSLFECFprocessing. When a borrower applies for PSLF,ATL2U
is used to create records for each ECFthat is sent to FLS. Additionally, if the borrower's loans are not with
FLS,the TL2U screen has a field by which FLSrequests the loans from other servicers.
Acronyms
ARC Action Request Code
BMF Business Master File
DCN Document Control Number
DOE Department of Education
ECF Employment Certification Form
EIN Employer Identification Number
ED Exempt Organization
FLS Fed Loan Servicing
FSA Federal Student Aid
IBR Income-Based Repayment
ICR Income-Contingent Repayment
IRS Internal Revenue Service
NSLDS National Student Loan Data System
0MB Office of Management and Budget
PAYE Pay As You Earn
PSECF Public Service Employer Certification Form
PSLF Public Service Loan Forgiveness
SSN Social Security Number
TLF Teacher Loan Forgiveness

OF INFORMATION ACT
Background
The Public Service Loan Forgiveness (PSLF)Program was established to encourage individuals to enter and
continue in full-time employment in lower-paying but vitally important public service jobs. The program
allows eligible borrowers to have the remaining balance of their Direct Loans forgiven after working full time
at one or more qualifying public service employer(s) for at least 10 years while making 120 qualifying monthly
payments after October 1, 2007.
Fedloan Servicing (FLS)has no specific requirement for the frequency of submitting the Employment
Certification Form (ECF); however, the general frequency guidance for submitting an ECFis once a year for
the prior year of employment to provide an update of the borrower's employment status. FLSalso
encourages borrowers to submit an ECFwhen they first express interest in the PSLFProgram and whenever
they change employers. ECFsubmittals allow FLSto track periods of qualified employment and the number of
qualifying payments.
Eligible Loans
The borrower must have at least one of the following types of Direct Loans with an outstanding balance
greater than $25 to qualify for PSLF:
• Federal Direct Stafford/Ford Loans (Direct Subsidized Loans)

• Federal Direct Unsubsidized Stafford/Ford Loans (Direct Unsubsidized Loans including TEACH Loans)
• Federal Direct PLUSLoans (Direct parent or student PLUSLoans)
• Federal Direct Consolidation Loans (Direct Consolidation Loans)
• Federal Direct joint (spousal) Consolidation Loans
• Special Direct Consolidation Loans
Qualifying Employment
The borrower must be employed full-time by a qualified public service organization(s) or serving as a full-time
AmeriCorps or Peace Corps volunteer while making the 120 qualifying payments.
1) Employment qualifies as full-time if the borrower is working in one or more jobs for the greater of:
a) An annual average of at least 30 hours per week (or for a contractual or employment period of
at least 8 months, an average of 30 hours per week); or
b) The number of hours the employer considers full-time, unless the qualifying employment is
with more than one employer.
2) The Public Service Organization must be one of the following:
a) A government organization.
i) Including a federal, state, local, or tribal organization, agency, or entity; a public child or
family service agency; or a tribal college or university
ii) Excluding a member of the U.S. Congress.
iii) Congressional staff members and state legislators (and their staff) may qualify, except for
any period of time that they work for a political campaign, (For that timeframe, the staffer
ceases to be a government employee and is considered to be working on behalf of a
partisan political organization.)

OF INFORMATION ACT
b) A non-profit, tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code;
which includes most not-for-profit private schools, colleges, and universities.
c) A private, non-profit organization (that is not a labor union or a partisan political organization)
that provides at least one of the following types of public service:
i) Emergency management
ii) Military service
iii) Public safety
iv) Law enforcement
v) Public interest law services
vi) Early childhood education (including licensed or regulated child care, Head Start, and State
funded pre-kindergarten)
vii) Public service for individuals with disabilities and the elderly
viii) Public health (including nurses, nurse practitioners, nurses in a clinical setting, and
professionals engaged in health care-practitioner occupations and health support-
occupations, as defined by the Bureau of Labor Statistics)
ix) Public education
x) Public library services
xi) School library services
xii) Other school-based services
Note: A non-profit organization only qualifies if a borrower's qualifying employment does not include
time spent on job duties that are related to religious instruction, worship services, or any form of
proselytizing.
3) Periods of employment must be certified on an ECF.
4) The ECFmust be complete, signed, and dated by an authorized official from a qualifying public
service organization.
The borrower must provide supporting documentation to show employment at a qualified public service
organization if the borrower is unable to obtain certification of employment at a public service organization
because it no longer exists. The borrower must provide sufficient evidence that:
• The employee was employed for a particular year (based on W-2 form). Because the borrower must
submit W-2 forms for every year being certified, we can use the EIN on the W-2 to help determine if
the employer qualifies.
• The borrower was engaged in paid employment for the indicated period (paystubs).
• The borrower was employed in a full-time/part-time position, as indicated on the ECF.
ECFis Imaged
The ECFcan be received by mail, email, or fax.
Imaging DOC ID - XBCR
Action Request Code: PSECF

OF INFORMATION ACT
Section 1: Employment Certification Form {ECF) Process

1.1 View Image
1) Access the image through FileNet Imaging. See File Net Imaging procedures for detailed sign in and
navigation directions.
a) Select "Workflow" from the first drop down menu.
b) Select "FLS Servicing Processor" from the second drop down menu.
c) Select the "Detailed Search" option.
d) Type the oldest processing date in the "date received" field, based on the daily PSECFVolume
email that is sent.
e) Type "PSECF" in the ARC field.
f) Select Search.
g) Select "View Item" on the first line that appears to select the oldest task.
h) Using a second FileNet session, search the borrower's Social Security Number (SSN) in both the
Processing and Review queues to work all PSECFsfor a borrower.
i) Verify that the image was logged to the correct SSN by comparing the SSN on the ECFto the
SSN listed in lmaging's SSNfield.
j) If the SSN does not match, proceed as follows:
i) Change the SSN in File Net to reflect the correct SSNfor the borrower.
ii) If there are documents attached to the ECFthat do not belong to the borrower or are to be
logged under a different ARC, in the Doc Comment box on the bottom right side of the
image add the words "Logging Error" as shown below.
Doc Comme-nt: _,:-~; ·a Errc-
iii) After the Doc Comment box has been marked with the words "Logging Error" send the
image to the Review queue by selecting Review in the top right corner of the image.
iv) No documents can be processed on TL2U.
v) Place the document in the "Review" queue in FileNet.
vi) Once the document has been fixed, the image will be placed back into WorkFlow to be
completed.
k) If a borrower provides multiple ECFsthat are included on a single DCN, the processor must
enter the information for all ECFsinto~ Refer to Section 1.8, Process/Update ECFScreen.
I) If the borrower provides multiple ECFsthat are logged on FileNet on the same day and page 1
is only included in one of the ECFs,use the same page 1 for all the ECFsthat were received on
the same day.
m) If a borrower sends in an ECFthat includes both page 1 and 2, and the ECFis denied and we
subsequently receive a revised page 2 (within 30 days from the stamped date of page 1) for
the same employer that supports/corrects the reasons for the denial, the revised page 2 of the
ECFmay be used to approve the ECF.
Example:
Page 1 = Doc A
Page 2 = Doc B

AMERICAN & Confidenti.il
FEDERATION OF TEACHERS UNDER THE FREEDOM P.ige I8
OF INFORMATION ACT
Page 2a = Doc C
Doc A and Bare received on 08/01/2013, they are denied on 08/05/2013. Doc C is received
on 08/20/2013 (within 30 days from the stamped received date of Doc A) and because Doc
C is for the same employer and corrects the missing information from Doc B, we are able to
piece the documents together to process and approve the ECF.
n) If a borrower sends in an ECFthat only includes page 1 and we receive page 2 within 30 days
(from the stamp date of page 1) and we have not pieced page 1 of the ECFwith any other page
2. We can piece the 2 pages together to process as one whole application, but only if the
borrower's name and SSN appears at the top of page 2.
Example:
Page 1 = Doc A
Page 2 = Doc B
Page 2a = Doc C
Doc A is received on 08/01/2013 and never used before. Doc Bis received on 08/20/2013;
Doc A and Doc B can be pieced together and processed as one whole application.
Doc C is received on 08/21/2013 we cannot use Doc A again to process as another whole
application since Doc A was already used and approved with Doc B.
If Doc A and B together are a denial for the same employer as Doc C, then we can process
Doc A and Doc C together to support/correct the denied application.
o) Verify that the form is Office of Management and Budget (0MB) approved.
i) An OMS-approved form contains the 0MB approval number and the form's expiration
date in the upper right corner of the first page.
ii) If the borrower sends a form that is not the OM 8-approved ECF(contains X's in the
expiration date, and X's in the OM B code field at top of form), deny the request (see
Section 1.8 Process/Update ECFScreen).
• Deny through the system for the reason that the borrower and the authorized official
did not sign the ECF.
• Place an 'N' in the "Borrower Signed" field and place an 'N' in the (authorized official)
"Signed" field.
• Enter 'Y' in the "Bypass Ltr" field to bypass the system denial letter.
• Send the" Denied Invalid ECFNot 0MB Approved" manual denial letter. This letter is
located in Knowledge Base. See Section 1.8 (Process/Update ECFScreen, step 7), send a
manual denial letter.
• Comment the employment entry, as we are unable to process an invalid form. See
section 1.9 Commenting.

OF INFORMATION ACT
2) If the Document received is illegible and you are unable to determine the information on page 2 of
the form, deny the ECFby leaving all applicable fields from Section 3 and/or Section 4 of the form
blank when inputting onto~
a) Place a 'Y' in the Bypass letter field
b) Send the "Illegible Fax - ECFReceived Letter" manual denial letter. This letter is located in
Knowledge Base. See Section 1.8 Process/Update ECFScreen, step 7), send a manual denial
letter.
1.2 Review Demographics

1) lfwe service a borrower's loan, ONLY compare and review the demographic information (address
and phone) on the form when one of the following is met:
• The box shown below on the form is checked indicating a change.
• The address or phone number on file is invalid.

SECTION 1: BORROWER IDENTIFICATION
Check this boK if an of our information has chan ed.

SSN
Date of Birth
Name
Former Name (if any]
Address
City, State. Zip
Telephone - Primary
Telephone -Alternate
E-m,,il (optional)
a) If one of the above criteria is met, compare the borrower signed date found on the form to the
last date verified (LASTVER) on the Borrower Demographic screen~.
Account more recent No changes necessary
Form more recent

Update demographic information using information on
Account demographics invalid the form.
b) When updating the email address, do not update the contact email address. The email address
should be added or updated to the home email address field.
c) If the borrower's loans are serviced by FLSand the name differs on the form from the name on
file, send the name discrepancy letter using thel(bl(5l I
d) Update minor variations (e.g., Kim/Kimberly, Mike/Michael)
2) If we are not servicing loans for the borrower:
a) Add the demographic information to ATL2U. See Section 1.8, Process/Update ECFScreen.
b) If the borrower provided a permanent address and a mailing address on the form, add the
mailing address tofbl(6l ~.

FEDERATION OF TEACHERS UNDER THE FREEDOMPage I 10
OF INFORMATION ACT
Note: If the borrower provides a previous/former name on the ECFand this is the only name showing
on NSLDSwith no history, then enter this name on~. (See the section below for instructions on
reviewing NSLDS.)
Example: Borrower lists Smith as their last name with a previous last name of Jones on the
ECF. If NSLDSlists the borrower's last name as Jones with no history of Smith, you must use
Jones.
3) If there is missing demographic information and we are not servicing loans for the borrower,
attempt to obtain demographics by contacting the borrower using the phone number provided.
a) If the SSN is missing, call the borrower to attempt to obtain the information.
(1) If no contact information is listed for the borrower, call the employer. As the SSN is
unlikely to be obtained from the borrower's employer due to privacy issues, ask the
employer to have the borrower contact FLS.Then, complete a PSCOMdocument to
notate the outbound call. See Section 1.9, Commenting. Proceed to section 1.3. If no
contact information is listed for the borrower, call the employer to obtain it.
(2) If no answer leave a message for the intended party with return contact information.
Be sure you are not calling before 8:00 AM or after 9:00 PM (their time). Always check
the location of the borrower to determine their time zone. If it is determined to be too
late to call the borrower or employer, place the image in the review queue in FileNet
and place the entry on hold on COMPASS5 M until you are able to call the next business
day.
Note: If you need assistance locating what time zone the borrower or employer is located in, please
refer to the map located in !Connect. Time Zone Dialing
(a) The message must include the following:
(i) Processor's first name.
(ii) Reference FedLoan Servicing.
(iii) Calling about a Public Service Loan Forgiveness form.
(iv) Advise to reference the reason for their call when they contact us (example: to
provide missing information).
(v) Leave the return number of 1-855-265-4038 and provide our hours of operation
(Monday- Friday 8:00 AM to 9:00 PM EST.)
b)(6)
(3) Update the Employer Outbound Call Tracking spreadsheet (located in

5
jtbl( l !Public Service Loan Forgiveness/Tracking Spreadsheets)
with processor's name, the borrower's first name, borrower's last name, date of the
outbound call and reason for the outbound call with the DCN number.

OF INFORMATION ACT
(4) Place the document into the review queue with a comment stating 'SSN missing, call
placed to the borrower.fbJ(6J I
(5) No further adjustments can be made as we do not have an SSN.
b) If the name or DOB is obtained from the borrower, complete a PSCOMdocument to notate the
outbound call. See Section 1.9, Commenting. Proceed to section 1.3.
i) If no answer leave a message for the intended party with return contact information. Be
sure you are not calling before 8:00 AM or after 9:00 PM (their time). Be sure to check the
location of the borrower to determine their time zone. If its determined to be too late to
call the borrower, place the image in the review queue in FileNet and place the entry on
5
hold on COMPASSM until you are able to call the next business day.
ii) The message must include the following:
(1) Processor's first name.
(2) Reference FedLoan Servicing.
(3) Calling about a Public Service Loan Forgiveness form.
(4) Advise to reference the reason for their call when they contact us. (Example: to provide
missing information).
(5) Leave the return number of 1-855-265-4038 and provide our hours of operation
(Monday- Friday 8:00 AM to 9:00 PM EST.)
b)(6)
iii) Update the Employer Outbound Call Tracking spreadsheet (located in

(b)(6) with
~--------------------------------~
processor's name, the borrower's first name, borrower's last name, date of the outbound
call and reason for the outbound call with the DCN number.
iv) Deny the form for the missing information applicable. See Section 1.8 Process/Update ECF
Screen.
v) When denying, ensure that you do not place an 'N' in the Eligible Loan field.
vi) Comment the call on TL2U. See Section 1.9 Commenting.
1.3 Review NSLDS

1) Open NSLDS.See NSLDSTraining Overview to review steps on how to open, log into, and navigate
NSLDS.
2) Review borrower's loan history on NSLDSAid tab to determine if borrower has at least one eligible
Direct Loan with a balance greater than $25.
a) If borrower does not have any eligible Direct Loans with a balance greater than $25, deny the
request for "no eligible loans" using the PSLF- No Eligible Loans Macro. See Section 1.4, No
Eligible Loans Macro.

OF INFORMATION ACT
b) If the borrower's Direct Loans are all listed as defaulted on NSLDS,deny the request.
i) Deny the request for "no eligible loans" using the PSLF- No Eligible Loans Macro. See
Section 1.4, No Eligible Loans Macro
ii) Select 'Y' in the "Bypass Ltr" field to bypass the system denial letter.
iii) Send the "Denied Defaulted Loans" manual denial letter. This letter is located in
Knowledge Base. See Section 1.8 Process/Update ECFScreen, step 7), send a manual denial
letter.
iv) Comment the employment entry that all loans on NSLDSare listed as defaulted and a
manual denial letter was sent. See Section 1.10 Commenting.
v) Archive the form. See Section 1.11 Archive Image
c) If borrower does have at least one eligible Direct Loan with a balance greater than $25, make
note of eligible loans, including the Department of Education (DOE) servicer for each loan.
An example of a DOE servicer is below:
D6 • DIRECT CONSOL SUB Status: RP as of 04/0112014

D I Loan Detail
Approved Amt: 521.639 Disbursed Amt: S21,467 □ OPB: S20.811 Agg. OPS: S20.811
Loan Date: 06/07/2012 Sep. Loan Ind: A Loan Period: NIA - NIA
Last Oisb. Date: 06127/2012 Last Oisb. Amt: S462 Acad. Lv: NIA
EO Servicer: DEPT OF ED/FEDLOAN SERVICING(PHEAA)- 579
d) Do not use a servicer code for a commercial servicer. A commercial servicer is listed with a GA
and a Servicer Code. These types of loans should not be considered for PSLF.
An example of a commercial servicer is below:
SF· FFEL STAFFORD SUB Status: RP as of 08/03/2005

I
m NOVA SOUTHEASTERN UNIVERSITY-DAVIE • 00150900
Loan Detail
Guaranteed Amt: $8,500 Disbursed Amt: $880 OPB: $755 Agg. OPB: $755
Loan Date: 04/0512005 Sep. Loan Ind: A Loan Period: 01104/2006 - 07/29/2006
Last Disb. Date: NIA Last Disb. Amt: $0 Acad. Lv: A
GA: USA FUNDS INC - 800
Servicer: NAVIENT SOLUTIONS INC. - 700191
3) If the borrower has at least one eligible Direct Loan, continue with a review of all DOE servicers
with which the borrower has loans (FFELPor DL). Review the loan details of the Direct Loans to
determine if they had more than one prior servicer.
Guaranty Agency I Lender I Servicer Agent History
Start End Code Name

Servicer Agent
03,15'2012 CURRE/JT 501 Qf:PT QF l;:_DE__
$_6 e_OFIL/b.UC_L,.\l
12105-'2008 0311.l,.'2012 583 IR~CT l.QArJ ~E;:RVICltlY C::.EJJTt;R,ACS Prior Servicer

OF INFORMATION ACT
a) View the details for all Direct PLUSLoans to determine if the loans are Direct parent PLUS
Loans.
b) If the borrower of the Direct parent PLUSLoan is not the person employed at the public service
organization, then the Direct parent PLUSLoan does not qualify for PSLFpurposes.
Example: A submitted ECFis for Paul Smith, and NSLDS(see screen shot below) indicates that
the Direct parent PLUSLoan was taken out by the parent, Jane Smith. The ECFfor Paul Smith
does not prove eligibility for Jane Smith's Direct parent PLUSLoan.
However, if we receive an ECFfor Jane Smith (the parent borrower), then the Direct parent
PLUSLoan may be eligible for PSLFif the borrower meets the qualifications.
Selecting Loan Details will bring up one of two different screens, depending on whether the
borrower is the student or a parent. The screens will appear as follows:
• Student Borrower:
PAULS SMITH
*** - ** - **** DOB: MM/DD/YYYY
II D4 - DIRECTPLUS
UNIVERSITYOF IOWA- 00189200
Status: RP as of Ol/12/201S
I Loan Details
I
Approved Amt: $8,000 Disbursed Amt: $8,000 OPB: $8,000 IAgg, OPB: I $0
Loan Date: 1112/2015 Sep. Loan Ind: A Loan Period: 01/2012015- 05/15/2015
Last Disb Date: 1/1512015 Last Disb. Amt: $8,000 Acad. Lv. 2 I
ED Servicer: DEPT OF EDIFEDLOAN SERVICING(PHEAA) - 579
Loan taken out by:

PLUS
JANEA SMITH
LOAN
*** - ** - **** DDB: MM/DD/YYYY
• Parent Borrower:

OF INFORMATION ACT
H JANEASMITH
DOB: MM/DD/YYYY
Loan Detail
Loan Last Updated: O-V27.'2015
Loan taken out on behalf of:

PLUS
PAULS SMITH
LOAN SSN: ***-**-**** DOB: MM/DD/YYYY
1.4 No Eligible Loans Macro

1) Access the MACRO through the LAUNCH PAD located on your desktop
bl-
LAUNCHPAD
l, WAPCLAUNCHPAO
Setting, Sesci □ n \'1ew Help
Recent
, AgentEffect,veness
Phone Tools
Process,ng Tools
a) Once the Launch Pad has open, expand the "Processing Tools" option
L WAPC LAUNCHPAD ~
1----==--I 11..,£3,,1
Settings Semen '/1ew Help
Favorites
+ Recent
+ Agent Effectiveness
+ Phone Tools
~=,,-,-,~o~f~~]nt
PSLF ECF No El1g1bleLoans
QA

FEDERATION OF TEACHERS UNDER THE FREEDOMPage
OF INFORMATION
I 15 ACT
b) Select "PSLF ECFNo Eligible Loans" option
1:_WAPCLAUNCHPAD ~ I El 'l•!r:i•I
Setting> Semon 'fiev, Help
Favorites
Recent
Agent Effectiveness
Phone Tools
Processing Tools
Econ Deferment
QA
c) Once the Macro opens two things will occur

i) The PSLFNo Eligible Loans Macro box will open and the HERAsession will change to the
WAPC Launch Pad version
PSLF
NOEUGJBL{
LO~NI
Publt $e,we LcaoForg·,aess ECF

Enie·a SSN:o pop, at, an ECF10danvfornoel1gb e loans
2) Enter the borrower's SSN in the "SSN" field of the macro.

3) Click on "Load Acct"
a) If the borrower has previously submitted an ECFor FLSis servicing loans for the borrower, the
borrower's demographic information will auto populate in the macro.
b) Make any necessary changes to the borrower demographics based on the new ECF.
i) Name (First, middle initial and last name)
ii) Address
iii) DOB
iv) City
v) State
vi) Zip
vii) Domestic Home Phone

OF INFORMATION ACT
viii) Domestic Alternate Phone

ix) Email
PSLf NO ELIGIBLELOANS
Public Service Loan Forg1vnessECF

Enter a SSN to populate an ECF to deny/or no el1g1bleloans
SSN 723-4S6739
FirstName JOHN Middle ln1tal
Last Name SMITHOZ DOB o-.'07.'7933

Address l 123 SESAME ST
Address 2
Address 3
City HARRISBURG State PA Zip lT02-

DomHmePhn (717j222-33-44 DomAltPhn _,1 __
Email BIGBIRD@YAHOQ COM
El1g1bleLns N BrmS1gned Date Signed
.S,ubm,tECF
c) The Eligible Loans field will automatically populate with an 'N'.

i) This indicator will need to be updated if the ECFis being denied for defaulted loans.
d) If all demographic information is now correct, select whether the borrower signed the ECF
from the drop down box.
PSLFNO ELIGIBLE
LOANS i.e_,i.;:;.J
Pubhc Serv,ce Loan Forg,vness ECF
Enter a SSN 10 populate an ECF lo deny for no el,g,ble loans
SSN :23-45-6789 !,_oadAcct
First Name JOHN ~11ddleln,tal R
Last Name SMITHOZ DOB Gl;Dl;l98S

Address l 723SESA~IEST
Address 2
Address 3
c,, HARRISBURG Stale CA ,,, 77702-
Dom Hme Phn (7171222-3344 DomAllPhn 1_) __
Email BIGBIRO§YAHOO COM
El1g1bleLns N • Brwr S1gn:~ate Signed
~
e) Select the date the borrower signed the form (if applicable) from the calendar.

OF INFORMATION
I 17 ACT
PSlFNO ELIGIBLE
LOAN\
P,bl•c s,,,,ce Loan r o,g,vne-,s f Cf

[a:e, a SSf.. ,o popolato '" [ ~• 10decy lo, ao el g b e loans
C,t,
Domr'1rePbn .-,,,122na, Doo,AtPhn __ _
Ecc,a,I blJbHUe'YAHOOl0>.1
ElgbeLns ~ • 5rv., S,gned Y
.Subm,lECF
;,1 ll 1: 1'
1' lb :==i
f) Ensure all information in the macro is true and accurate based on the ECFreceived.
g) Click the "Submit ECF" on the macro
i) This will deny the ECFfor no eligible loans. A message indicating that the request was
denied and a letter was sent will appear.
ECF DENIED
REQUESTDENIED.LETTERSENT
OK
ii) By clicking "OK", this will clear all fields within the macro.
PILFNO ELIGIBLE
LOANS
o,,c,1c Se,v,ce I nan f mg"n~ss fr'

Cn·e· a $ii~ to populate an [,~, io deny fo, oo ehg,bl~ oan,
h) Archive the ECF (See Section 1.11 Archive Image) and move to the next ECFto be processed
from Workflow.

OF INFORMATION ACT
Note: The macro will notate the employment entry with the following information.
BORROL·JERSSN: DOB: 01 01 1990 FORM STATUS:
NAME: JANE A DOE
ADDRESS: 1200 N 7TH ST HOLD/REVIEW: N
ADDRESS: ELIGIBLE LOANS: N
ADDRESS: CHANGE REASON:
CITY: HARRISBURG STATE: PA ZIP CODE: 17010
FGN ST: ==-=~=~=c. FGN CD: FGN CNY:
DOM HME PHN: AC 717 EXCH 720 LCL 1234 DOM ALT PHN: AC EXCH LCL
FGN PHN: CNY CTY LCL
EMAIL: .JANE.A.DOEl<lPHEEA.COM
BORROL~ER SIGNED: Y DATE SIGNED: 04 01 2016
EIN: 999999999 EMPLOYER NAME:
EMPLOYMENT BEGIN DATE: 11 11 2011 EMPLOYMENT END DATE: 11 11 2011
EMPLOYMENT STATUS: F HOURS PER ~•JEEK: 0. 00
TYPE OF PUBLIC SERVICE: GO TYPE OF NON-PROFIT: ADDRESS PRVD: Y
AUTHORIZED NAME: DTE SGND: 11 11 2011
TITLE: SIGNED: Y ACCEPTABLE: Y
DOM PHN: AC 717 EXCH 222 LCL 2222 EMPLOYER APPROVED: Y
FGN PHN: CNY CTY LCL EMPLOYER OVERRIDE: N
SERVICED AT: PRIOR SRV: ROST □ OT: BYPASS LTR: N
1.5 Review Document

1) Determine if all of the required fields below are populated in Sections 1 through 4.
a) Section 1: Completed by the borrower.

P'ea,e erte• or c,:;-,ect t~e fo'low,ng ,rfcrma'.,c..,
D Check this box if ,iny of your inform;ilion h,is ch;inged.
SSN
Date of e,rt~
Na-re
Forrrer '-,JaMe 1,f an,']
Addre11
c,t,i. Sta•e.
Teleoh:>ne - Pri..,,ary
Zo
---------·--- ----
Te· ep~cCJe - Alter'la~e
E-n·a I lco:1,)na J
i) Required information (if missing, deny the request):

(1) Social Security Number
(2) Date of Birth
(3) First and Last Name
ii) Information not required (if missing, don't deny request, verify/update the demographics
5
on file within COMPASSM):
(1) Borrower address
(2) Borrower phone number
(3) Borrower email address
b) Section 2: Completed by the borrower.
i) Required Information - Borrower signature.

OF INFORMATION ACT
I Borrower Signature _________________ Date
ii) If the borrower's signature is missing, deny the request. See Section 1.8
Process/Process/Update ECFScreen.
(1) For a digital/electronic borrower signature, refer to Appendix C for guidance on
determining if the signature is acceptable to use.
(a) In the 'doc comment' field in workflow, type "DIGITAL SIGNATURE".
(b) Move the image to the review queue in File Net.
(c) Send an email to the "FLS PSLFSupervisor Review" mailbox.
(i) Subject of the email should be "Digital Signature"
(ii) Body should include the borrower's SSNand that the ECFneeds reviewed for
eligibility.
iii) Information Not Required - Signature Date. If the date signed is invalid or missing, enter
the FileNet Imaging RECEIVEDDATE.
Note: At this time we currently accept 4 versions of the ECF. Two versions have an expiration date
of 11/30/2014. This form was released twice. In the first release, the employment dates were
listed as DD-MM-YYYY. In the second release, the employment dates were switched to MM-DD-
YYYYand the language regarding full-time hours not being part of proselytizing was modified. Two
versions have an expiration of 12/31/2017. This form was released twice. In the first release, the
form contained box 15 in Section 4. In the second release, the box 15 was removed from Section
4.
c) Section 3: Completed by the employer for the form with an expiration date of 11/30/2014.
Section 3: Completed by the borrower or employer for the form with an expiration date of
12/31/2017.
d) Section 4: Completed by the employer (only found on the form with an expiration date of
12/31/2017).

OF INFORMATION ACT
5ECrlCW' CEA'r!".'C~ TTOH0" EJIPLO"111EHT

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FEDERATION OF TEACHERS UNDER THE FREEDOMP.ige I 21
OF INFORMATION ACT
.. ' '•' ' .
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f loan PSLFECFProcessingProcedures
OF INFORMATION ACT
SECTION 3: EMPLOYMENT INFORMATION (TO BE COMPLETED BY THE BORROWER OR EMPLOYER)
1. Employer Name: ______________ _ 10. Is your employer a tax-exempt organization under

section S0l(c)(3) of the Internal RE>venue Code'
2. ~ed.-ral tmployer Identification Nrnnbe, (tlN): D Yc•s Skip to Section 4

0No - Cont11lUE'to Item 11.
Your employer", EIN may be found on your Wage and 11. Is your employer a not-for-profit organization'
TdX Stalt'rnt'fll (W·l). 0Yt's - Cont111Ut' to llt'm 12.
3. Employer Address: D No -Your E'mployE'r dOE'S not qualify.
12. Is your employer a partisan political organization'
0Y<cs - Your employer dew<, not qualify.
4. Employer Webs1\t' (if any) D No - Continue to Item 13.
13. Is your employer a labor union?
S. Employment Begin Date: 0Yes - Your employer doe> not quality.
0 No Continue to Item 14
6. Employment End Date: 14. Do<cs your employer provide any of the b<clow
________ OR s<crvices?
□ '>till <"mploy<"<i Dy,., - ~f'lect ;ill thf' <,f'rvires your f'mployer
7. EmploymentSldtus:Ofull TimeOPart Tirllt' provides and then continue !o Section 4.
8. Hours Per Week (Average)· ________ _ • ~ Emergency management

• Military service (see Section 6)
In dude vacation. leave time. or any leave L,ken under • Public <,;ift'ly
the r arrnly Medical Le.Jve Act of 1993. If your
• Law E'nlorc<crnent (see Section 6)
employer is a 501(c)(3) or a not-for-profit
• Public interE'st legal servicE's (5eE' Section 6)
organization, do not include any hours you spent on
• Early childhood E'ducation (see definition of
religious instruction, worship services, or "public service org,rnization·· in SeClion 6)
proselytizing. • §Public servicf' for individu;ils with disabilities
9. Is your employer a governmental organization) • Public SE'rvice for the elderly
A governmental organi,ation is a Federal. State, local. • Public health (sf'e definition of "public ,;ervke
or Trib.JI government org,rniz,1!ion, agency. or entity. a oreani1;ition'· in Section 6)
public d11ld or farrnly s.-rvice agt"ncy, a l!ibal collt"g.- •~Public education
or university, or the Peace Corps or AmeriCorps. • Public library services
• School library services
0Yes - Sk,p to Section 4.
• Other school lMsed services
D No Continue" to Item 10.
D No - Your employer doe, not qualify.
SECTION 4· EMPLOYER CERTlflCATION (TO BE COMPLETED BY THE EMPLOYER)
l S. DI ce,:,t, Iha'. the ,nl~ rmat1-~ r r S'.'ct c,n 3 s Ir Je comp e:e a~.:J -:c,r·e :: :o the bes'. o' m, ~ rc,·,•.leCfe a~d b'.': ,ef
Jn:i :hat Jr1, ar JJ'.r'cr :ed o'!,: al ,;'.~e Sec: or· 6, cft•,~ o•~Jn,:.it on ·1a·11~(t,r. Se'.t,~n 3 Complet('lltnl~ 16- 21,
lJ. Ca'.e

AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOMPage
& Confidential OF INFORMATION
I 23 ACT
SECTION
3: EMPLOYER
INFORMATION
(TOBECOMPLETED
BYTHEBORROWER
OREMPLOYER)
10. Is ycur -:'mployertax-exeript Jrdtr Section 501 (clO)
Ccce7
of the lnt-:'rnalR-=venJ-:'
D Yes- Skip to Section 4
_J \,:; - C,:;ntlnLeIG 1:-=ri11
1
11. Is ycur employer a not-for-profit crgan1zat1on
Your emp101en EINmai be 'oJnd en your 'Sage I Yes-C,:;ntinLe:c lt-=m 12
and Ta, Statement :W 21
C:No - Yo~r e11plcyerdoe1 not qL1ahfy.
1
12. Is ycur employer a part11anpoli:1calcrgan1zat1on
L Yes-YoJrempcyerdoesnotqualrfy
No - (c~tinJe :c lt-:'IT'13.
a labor u111oni
13. ls your -:'111ploy-:'r
5. :11ploymer,'. Begin )o:e

n V,:s- YoLremplcyer does rot cualify
D No - Continu-=to Item 14.
14. lndica:e 11,h1ch
S-:'rviceor se•v1c-:'s
your employer
6. :11ploymen'. Erd Date: prcvides a1d then cor'.irue to Section 4. '
appropriate'
OR Emergerr:y maragemen'.
S:ill Employ-=d Mili:ory 1erv1c1:
1SeeSect en 6.
7. Employmtnt Stat.is _J Full-Tim-:' L Jart-T1r1e Public safety
La·,•,•
e1forcement
8. •kur1 Per',lieek 1A~1:rag1:,
Public interest legal se'Vices,S-=eSernc:n6,
Include ,•.:,cat1on.
l-:'avet 11e,Of ary eave taken
under the Family Medical Lea·,eAct of 1993 If your Earlychilc:1oc,deduca:1cn :SeeSection 61
): or a nc•'.-for-prd1tcrgan1L:Jt101,
empl,;)'er 1sa SC1,:c11 Public servicefor 111d1v1duJI-;
w,th d1sJbil,:,es
do not ,rclJde any r0Jr1 yoJ spent on tt-hgious
Public servicefor 11"-e
elderly
instru,tion, worship servin~s, or proselytizing
Public health :SeeSe::t1016:-
1
9. Is yo Lr employer a governnient.il organiz.:;'.1cn
Publ1ceduca: en See Section 6.1
Ago,·ernriental c ·ganization is a Federa S:ate.
Public library st-vices
local. Of Tribal government cr:;ianizat1on,agency, or
entity a oubl1cchild or family 1erv1ceagency, a -r1bal Scrcol l1brar,·se'VICi:I
cclltge or un1vers1:y. or the PeaceCoros or Ot1er scrcol-::iasec ser.-ices
=
A-n-:'r1Corp1.
Yes- Skip '.c Sec'.1cn4.
Ne - Contin Le to '.eM I 0.
None cf :he above -your employer dcts not
QuJl1fy
SECTION
4:EMPLOYER
CERTIFICATION
{TOBECOMPLETED
BYTHEEMPLOYER)
Bys1-~11ng. I certify th.:,tti---:'infcrrna:1c111 Sect1cn3 1strue'.::0mplete.and corr-:'Cttc the ::,estof my hcwledge .:,ndbelief
JnC:thlt I an- an authorized official ,:seeSec'.1cn6. of the c•gan1zat1on namec:1nSenion 3 Complete the rest of this Section.
Not!f II any cf t~e infcrma'.1cns c·cssed out or altere-din Section 3,ycu riu;t 1nit1al those changes
Auth;11zedOiirnl i Phone
Authorized Oflirnl's Erna1
Au1horizt-d Offlo.il's Signature D.ite

------------ -------
NOTE: No box 15 is present in Section 4 above.
f loan PSLFECFProcessingProcedures
OF INFORMATION ACT
g) Required Information for Sections 3 and 4 (as applicable).

(1) Name of the organization
(2) Employer Identification Number (EIN)
(3) Address of the organization
(4) Start date of the borrower's employment
(5) End date of the borrower's employment
(i) Employment Certification Prior to 10/1/2007- If ECFcertifies that the entire
public service employment period occurred prior to the start of the PSLF
Program (10/1/2007), do not approve the employment. Deny the request
because there is no reason to track employment for time periods in which
payments will not be reviewed.
5
1. Deny through the COMPASS M system with the reason for invalid dates.
COMPASS5 M does not deny for this reason at this time; to deny the ECF,flip
the dates of employment to show the end date of employment as the begin
date and the begin date as the end date. This will then prompt the system
to deny for the reason of invalid dates. See Section 1.8, Process/Update ECF
Screen.
2. Enter all other information provided in Section 3 on TL2U as it is listed on
the ECF.See Section 1.8, Process/Update ECFScreen.
3. Bypass the system denial letter (see Section 1.8, Process/Update ECF
Screen) and send the "Employment Certification Prior to 10/01/2007"
manual denial letter. See Section 1.8, Process/Update ECFScreen, step 7).
Send a manual denial letter.
4. Comment the denial and indicate a manual denial letter was sent due to
employment was prior to 10/1/2007.
(ii) If the borrower consolidated into a Direct Consolidation Loan but was
previously denied for not having Direct Loans, check to ensure the ECFbeing
worked is a new form with employment after the disbursement date of the
Direct Consolidation Loan and not the same form that was previously denied for
not having Direct Loans.
1. If the borrower falls under this scenario, and the same form was submitted
twice, deny the ECF.
2. Deny through the system by placing 'N' in the borrower signed fields.
3. Enter 'Y' in the "Bypass Ltr" field to bypass the system denial letter.
4. Send the "Consolidated New ECFRequired" manual denial letter. This letter
is located in Knowledge Base. Proceed to Section 1.8 Process/Update ECF
Screen, step 7) Send a manual denial letter.
(ii) If the employment dates are before the disbursement date of the first eligible
Direct Loan, deny the ECF.
1. Deny through the system by placing an 'N' in the eligible loan field.
2. Enter 'Y' in the "Bypass Ltr" field to bypass the system denial letter.
3. Send the "Employment Prior to Disbursement" manual denial letter. This
letter is located in Knowledge Base. Proceed to Section 1.8 Process/Update
ECFScreen, step 7) Send a manual denial letter.
(6) Employment status: Full-time or part-time status must be checked

OF INFORMATION ACT
(7) Average number of hours per week.

(8) Authorized Official's Name (printed)
(9) Authorized Official's title
(10) Authorized Official's signature
(a) If missing, deny the request.
(b) If signed, review to see if it is a physical or electronic signature.
(i) If the signature is physical, proceed with processing the document.
(ii) If the signature is a font or indicates that is was 'Electronically Signed' (see
Appendix C: Digital Signatures, which provides further guidance on which forms
of electronic signatures we accept), deny the request. To deny the request:
1. Deny through the system for the reason that the borrower signature was
missing.
2. Bypass the system letter, and send the 'Digital Signature- Employer' manual
denial letter. See Section 1.8 Process/Update ECFScreen.
(iii) If in doubt: Send an email to the "FLS PSLFSupervisor Review" mailbox.
1. Subject of the email should be "Electronic Signature"
2. Body should include the borrower's SSNand that the ECFneeds to be
reviewed for eligibility.
(c) Ensure appropriate Human Resources representative signs all ECFsfrom PHEAA
employees.
(i) Only the Senior Vice President of Human Resources is authorized to sign PHEAA
employee ECFs.
(11) Authorized Official's telephone number
(12) Signature date. If missing, deny the request. See Section 1.8 Process/Update ECF
Screen.
(13) Box 15 - On 2/17/2016, the Federal Student Aid (FSA) released an updated PSLFECF.
The updated form includes Revised Pay As You Earn (REPAYE)language as well as the
removal of Box 15 in Section 4.
(i) If the older form (with box 15) is received with Box 15 not checked, deny the
form per protocol.
(a) If the new form with an expiration date of 12/31/2017 is received and box 15 in
Section 4 is not checked, we are unable to approve the request. The employer
must check this box to indicate that the information in Section 3 is true/complete.
(i) Check to see if the unable to obtain certification box is checked on page one of
the ECF.If this box is checked, do not deny the form for box 15 not checked,
proceed to (15) Unable to obtain certification.
(ii) Deny the ECFthrough the system by leaving the following fields blank:
1. Employer name
2. EIN
3. Employment begin date
4. Employment end date
5. Employment Status
6. Hours
7. Authorized Official Name
8. Authorized Official Title

OF INFORMATION ACT
9. Authorized Official Phone number

10. Authorized Official Date signed
(iii) Place a 'Y' in the "Borrower Signed" field
(iv) Place a 'N' in the following fields
1. "Address Prvd" field
2. "Authorized Official Signed" field
3. "Acceptable" field
4. "Employer Approved" field
(v) Enter 'Y' in the "Bypass Ltr" field to bypass the system denial letter .
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(vi) Send the "Denied - Box 15 Not Checked" manual denial letter. This letter is
located in Knowledge Base. Proceed to Section 1.8 Process/Update ECFScreen,
step 7) Send a manual denial letter.
(vii) Comment the denial and indicate a manual denial letter was sent due to box
15 was not checked.
2. If an ECFwas previously denied for box 15 not checked and the same ECFis
returned with box 15 now checked, check to see if the Authorized Official initialed
the change.
(i) If box 15 is now checked and the Authorized Official initialed the change, we
can approve the ECF.
(i) If box 15 is now checked but the change was not initialed by the Authorized
Official, call the Authorized Official to verify that all information in Section 3 is
true.
1. If contact is made with the Authorized Official, comment the information to
the account. See Section 1.9 Commenting. Proceed with processing the
document.
2. If no contact is made, the form must be denied.
a. Deny the ECFthrough the system by leaving the following fields blank:
i. Employer name

OF INFORMATION ACT
ii. EIN
iii. Employment begin date
iv. Employment end date
v. Employment Status
vi. Hours
3. Comment the phone call and denial. Indicate the ECFwas denied because
box 15 was checked, but the change was not initialed by the Authorized
Official.
Note: If the borrower alters information in Section 3 and initials the change, as long as this is the first
time we received this ECF,Box 15 is checked and Section 4 was signed by an Authorized Official, we
can approve the ECF.
(14) Type of Public Service Organization

(a) Form expiration date of 11/30/2014: one of the first three boxes (a - c) should be
checked. If box c is checked, one or more types of public service must be checked.
(b) Form expiration date 12/31/2017: Questions 9-11 need to be answered yes or no.
(i) If ALL three questions (9-11) are answered 'No' you can automatically deny
these without escalating through the Employer Database. By all three boxes
checked as 'No', the borrower and official are certifying that the employer is
indeed for-profit.
1. Deny the request by placing an 'N' in the "Employer Approved" field.
Note: If all three questions are not answered 'No', the employer should still be reviewed following
normal procedures. See Section 1.6 Review Employer Websites/Directory.
(cl If questions 12 or 13 on the new ECFwith an expiration date of 12/31/2017 are answered
"Yes", these requests can be automatically denied without escalatingthrough the Employer
Database. By these boxes being checked as "Yes", the borrower and official are certifying
the organization does not qualify.
1. Deny the request by placing an 'N' in the "Employer Approved" field.
(d) If any information is altered, the borrower or employer, as appropriate, must initial
next to the change. If no initials are present, attempt to call the borrower or
employer, as appropriate, directly to obtain the conflicting or altered information.
(15) Checked box indicating unable to obtain certification.
(a) If the borrower checked this box, perform a Google search to verify if the place of
employment is currently operational.
(i) Unable to Obtain Certification box for form with Expiration date of 11/30/2014
Instructionsfor BorrowerwhenthereIs no AuthorizedOffIcIal:
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(ii) Unable to Obtain Certification box for form with Expiration date of 12/31/2017
7 Check this box if you cannot obtain certification from your employer because the organization is dosed or because
the organization has refused to certify your employment. The Department will follow up to assist you in getting
documentation of your employnient. Complete section 3, but do not complete Section 4.
(b) Open Internet Explorer and type organization's name into Google and press ENTER.
(c) Click on organization's website.
(d) Place a call to the organization using the "Contact Us" phone number located on
their website.

OF INFORMATION ACT
(i) If the organization is still operational, deny the request. To deny the request:
1. Deny through the COM PASS'Msystem for the reason that the certification
sections were not completed. Leave all COMPASS'Mfields in the certification
section blank. See Section 1.8, Process/Update ECFScreen.
2. Bypass the system denial letter and send the "Incomplete or Missing
Certification" manual denial letter. (See Section 1.8, Process/Update ECF
Screen, step 7): Send a manual denial letter).
(ii) If the Google search indicates the organization is closed, review the ECFto see if
additional documentation was provided:
1. If additional documentation was provided, email the "FLS PSLFSupervisor
Review" mailbox.
2. Include all attachments in the email.
3. If the borrower did not include additional documentation with the ECF,call
the borrower and request they send in documentation such as:
a. W-2s for time periods employed (Required)
b. Paystubs
c. Any other documentation that would support their request.
(e) If the Google search does not yield results for the employer, send an email to the
FLSPSLFSupervisor Review in box for a determination.
(i) A Lead and/or Compliance will review the documentation to determine if it is
sufficient to approve the organization as a qualifying employer.
1. If the organization can be approved,
a. Use the information listed in the email to approve the ECF.See Section
1.8 Process/Update ECFScreen.
b. The Lead or Supervisor will archive the email response.
2. If the information is not sufficient, the email will advise what actions are
needed. Denythe ECFfor the missing information in Sections3 and 4 if the ECF
with an expiration date of 12/31/2017 is received.
(f) If the borrower has been denied previously and is now escalating due to the
employer refusing to complete the form, send an email to the FLSPSLFSupervisor
Review mailbox to have the ECFreviewed by Compliance. Note that Compliance
will only review the ECFif the documentation is attached (e.g, a W-2 form).
Documentation must be requested if it is not already provided.
(16) Missing/Conflicting Information
(a) Attempt to call the employer directly to obtain the missing/conflicting information
if any of the following information is missing or conflicting from Section 3 or 4 of
the ECF.
(i) Name of the organization
(ii) EIN
(iii) Address of the organization
(iv) Start date of the borrower's employment
(v) End date of the borrower's employment
(vi) Employment status
(vii) Average number of hours per week
(viii) Authorized Official's name

OF INFORMATION ACT
(ix) Authorized Official's title

(x) Authorized Official's telephone number
(b) If the new ECFreceived conflicts (EIN, dates of employment, hours or status) with
an ECFrecord already approved for the borrower for the same employer, a call to
the employer to verify the correct dates, hours and status is required.
Example: Record for SSN: 123-45-6789
Previously Approved ECF:

Penn State Hospital
Begin Date: 01/01/2010 End Date: 06/30/2012 Status: FT 40 hours
New ECFreceived reflects:
Penn State Hospital
Begin Date: 03/20/2010 End Date: 06/30/2012 Status: FT 40 hours
A call to the employer to verify the correct begin date of employment is
required.
(i) Use the obtained information to process the request.
(ii) Comment the outbound call.
(iii) If we have loans for the borrower, comment the call through bJ(Bl
(iv) If the borrower is not on our system, comment the call on (bl(5l
~-~
(v) In no answer leave a message for the intended party with return contact
information. Be sure you are not calling before 8:00 AM or after 9:00PM (their
time). Always check the location of the borrower/employer to determine their
time zone.
1. If it's determined to be too late to call the borrower or employer, place the
image in the review queue in File Net and place the entry on hold on
COMPASSsMuntil you are able to call the next business day.
(vi) The message must include the following:
1. Processor's first name.
2. Reference FedLoan Servicing.
3. Calling about a Public Service Loan Forgiveness form; include the borrower's
name and the missing information.
4. Advise to reference the reason for their call when they contact us (example:
to provide EIN for John Smith).
5. Leave the return number of 1-855-265-4038 and provide our hours of
operation (Monday- Friday 8:00 AM to 9:00 PM EST.)
b)(6)

OF INFORMATION ACT
greatly appreciate it. Our number is 1-855-265-4038 and we are open Monday through
Friday, from 8:00 am to 9:00 pm Eastern Standard Time. Thank you.
6. Update the Employer Outbound Call Tracking spreadsheet (located in

(b)(6)
Spreadsheets) with processor's name, the borrower's first name, borrower's

last name, borrower's SSN, Employer name, Authorized official's name, date
of the outbound call and reason for the outbound call.
7. Deny the ECFthrough the system. This generates a denial letter that
includes a new ECF.The missing information is listed and the letter explains
the steps the borrower may take to have the ECFreconsidered. See Section
1.8 Process/Update ECFScreen.
Note: When the employer or borrower calls with the requested information, the phone
representative updates the outbound call tracking spreadsheet and submits a request to have the ECF
processed.
- If we have loans for the borrower, the phone representative submits an RVECF
task.
If the borrower is not on our system, the phone representative emails the SSN
and information to the "FLS PSLFSupervisor Review" mailbox to have the ECF
processed.
7) Requests to override judgment of denied employer.
a) The borrower or employer must provide a request and appropriate documentation in writing
to support the employer's qualifying status if the employer or the borrower requests
reconsideration of its organization/employer after an ECFwas denied. Examples of acceptable
documentation include:
ii) Proof of employer's not-for-profit status from federal or state government or
regulatory/taxing body;
iii) Articles of incorporation/charter; or
iv) Implementing legislation.
b) If additional information is provided, ~(b~l(~--------~
61
i) Email the documentation to the' mailbox.
ii) 6
Include fbl( l ~nthe subject line.
Note: The request is then forwarded to Compliance for review. Compliance will escalate to FSA, if
necessary.
iii) Place task in a "Review" status pending the outcome of Compliance's review. The
processor will be notified by email on how to proceed once the review is completed. See
Section 1.7, ECFUnder Review.
iv) Complete request based on outcome of Supervisor/Compliance/FSA review.
c) If Compliance/FSA's review approves employer's PSLFeligibility:
i) Correct the current ECFrecord to reflect a 'Y' in employer approved field. See Section 1.8,
Process/Update ECFScreen.
ii) Document TL2U comment screen with the details of the determination and that approval
has been provided by Compliance or FSA,as applicable.

OF INFORMATION ACT
iii) Approve the ECFform and the system will generate the approval letter to the borrower.
See Section 1.8, Process/Update ECFScreen.
d) If Compliance/FSA's review denies employer's PSLFeligibility:
i) Comment the account with the denial reason and a detailed comment as to why the
employer is still denied.
ii) Contact the borrower by phone to advise the override request is denied and give the
reason provided by Compliance/FSA.
iii) If unable to contact the borrower by phone, request a special letter (to provide
information regarding the denial).
(1) For FLSborrowers, submit the PSDNLARC in ATD22
(2) For non-FLS borrowers, send an email to the "FLS PSLFSupervisor Review" mailbox.
8) Attached certification - If the ECFis not completed and the employer attached the certification,
deny the request. To deny the request:
a) Deny through the COMPASS'Msystem with the reason that the certification sections were not
completed. See Section 1.9, Sending A Manual Letter.
b) Leave all the COMPASS'Mfields in the certification section blank.
c) Bypass the system denial letter, and send the "Attached Certification - Action Required"
manual denial letter (see Section 1.8 Process/Update ECFScreen, step 7). Send a manual denial
letter).
9) If Section 4 of the ECFis signed and completed by an authorized official but Section 3 has missing
information, that they attempted to provide in the attached documentation, first attempt to
contact the employer to obtain the missing information. If your attempt is unsuccessful, deny the
request.
a) Deny through the COMPASS'Msystem with the reason that the certification sections were not
completed. See Section 1.9, Sending A Manual Letter.
b) Deny only for the missing information that was not provided but attached in a separate
document.
10) Escalated situations- If processing a request from a borrower who has escalated because their
ECFwith attached certification was denied, send an email to the "FLS PSLFSupervisor Review"
mailbox. Include all attachments in the email by exporting the images. Refer to File Net Imaging
procedures.
11) Self-Certified - Review the account to determine if the borrower is escalating their request.
a) If not, deny the request.
i) Deny through the COMPASS'Msystem with the reason that the authorized official is not
acceptable to certify. See Section 1.9, Sending A Manual Letter.
(1) Ente~b)(61 lfield.
6l
(2) Enter~(bl( held. The system will generate a
denial letter to the borrower indicating the authorized official is not eligible to certify.
b) Escalated Situations - If the borrower indicates that they are the sole owner/operator of their
organization and there is nobody available to certify their form, FLSwill consider their request
pending receipt of supporting documentation.
i) Email borrower's requests to the '~(b~l(~61--------~,, mailbox. These will be
considered on a case-by-case basis.
ii) Include all supporting documents in the email. The supporting documentation must
include:

OF INFORMATION ACT
(1) W-2 (Required)

(2) Paystubs
(3) Proof of not for profit status
12) Employer requesting FLSto obtain employment from another source - Determine if the employer
is requesting us to access the borrower's verification of employment from another source (such as
a website). Deny the request. To deny the request:
a) Deny through the COMPASS'Msystem for the reason that the certification sections were not
completed. Leave all the fields in the certification section blank. See Section 1.8,
b) Bypass the denial letter (see Section 1.9, Sending A Manual Letter, step 7): Send a manual
denial letter) and send the "Unable to Obtain Certification" manual denial letter.
1.6 Review Employer Website/Directory

The PSLFDatabase contains a list of employers who have been escalated for further review. An
employer can show one of 4 statuses: approved, denied, inconclusive, or currently under review. If
unable to determine if an employer qualifies for PSLF,the record must be added to the database.
1) Open Employer Database

a) Access the MACRO through the LAUNCH PAD located on your desktop
bl-
LAUNCHPAD
l, WAPCLAUNCHPAD " I I", 11..,£3,,1

Setting, Sesci □ n \'1ew Help
Recent
, AgentEffect,veness
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b) Once the Launch Pad has open, expand the "Processing Tools" option

OF INFORMATION ACT
t -TESTING- WAPC.,.□ I 1-l 11..:;.1

Settings Sm1cnV1el'I Help
Favorites
Recent
AgentTools
PhoneTools
PSLFOrganization
Database
PSLFOrganization
Database
(Adrr
TaskAssignment
QA
c) Select "PSLFOrganization Database" option
Settings Srn1onVie·,s, Help
Favorites
Recent
AgentTools
PhoneTools
P.
PSLFOrganization
Database
rgan1za
10n a a ase drr
TaskAss1gnment
QA
2) Search for the organization on the ECFusing the search feature on the database.
a) Click Clear Filter, located at the bottom of the database, to ensure the entire database is
searched.
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b) Select 'EIN Filter'.

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c) Enter the EIN in the 'Search' field, and press 'OK'.

OF INFORMATION ACT
Enter EIN
Enter EINto fitter by.

OK
Cancel
d) Press the Clear Filters button and delete the previous information in the Search field if
performing multiple searches.
e) Select the view details button to view the details regarding the status of this employer
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Note: Many government agencies use the same EIN but are not affiliated with one another. If you are
able to determine that the organization is operated as government but is listed under a different
name and same EIN, you can approve the organization as GO. This will help eliminate un-needed
reviews in the PSLFDatabase.
Example: The employer on the ECFhas an EIN of 586000134. A search for the ElN yielded the
highlighted EIN; the database already lists the organization for this EIN. The View Details window
indicates that the employer associated with the ElN, Atlanta Public Schools, is approved as a
government organization.

OF INFORMATION ACT
b)(6)
IATLANTArusuc scrooLs
• ]5860D0134IATlANT~ I l'2&'2C12 I l'2s,2012 Ic 132S2012 1PH193%1·,,eo._,.,.,
P"h s,,,.,,c~ O,o Puh s~n"c~ O,o

lJMe, R.,.,ew -
I P"h Sen,,c~ O,o I Puh "~"""'"
Unde>, R""oew -
O,o
IJnrle, Re-,ew -
ll€n,ed
Sup,,.,,,,,. C'.ompl,~nce FSA
3) If the organization (with same name, location, and EIN) has already been approved or denied (and
no additional documentation was provided) within the previous year, continue with processing
the ECF;it is not necessary to review the employer's eligibility again.
4) If the organization (with same name, location, and EIN) has a status of inconclusive, follow the
steps below:
a) If we received W-2s or proof of their non-profit status, comment the DCN of the correspondence in the
New Comment section of the employer entry and send a screen shot of the Database entry to the FLS
PSLFSupervisor Review mailbox to have it further reviewed.
i) Include all attachments in the email by exporting the images. Refer to FileNet Imaging
procedures. If additional information is needed the email will be responded to.

AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOMPage
& Confidential OF INFORMATION
I 36 ACT
ii) Once a decision is made, the entry will be returned to you in the database. Process the ECF
according to the guidance provided. Refer to Section 1.8 Process/Update ECFScreen.
(1) If the employer is approved for a certain timeframe but denied for another, you will
need to add two separate records. One record will be for the approved timeframe, the
other will be for the denied timeframe. Ensure the account is commented thoroughly if
a new ECFis received for the same employer, but for a different borrower, and no
additional documentation is received.
(2) If the employer must be denied, follow the guidance placed in the comment history of
the database on how to deny the borrower on~
(a) If a manual letter is required, send an email to the FLSPSLFSupervisor Review
mailbox to have a manual letter drafted. In addition, include a screen shot of the
database entry for the organization.
b) If a new ECFfor the same borrower, same employer with different dates of employment and
no additional documentation is received:
i) Follow the guidance placed in the comment history of the database on how to deny the
borrower onl(bl(5l I.
ii) Send an email to the FLSPSLFSupervisor Review mailbox to have a manual letter drafted.
In addition, include a screen shot of the database entry for the organization.
c) If an organization is in an inconclusive status because Compliance is able to approve the
organization in part (for example, if the organization gained or lost their 501(c)(3) status so not
all employment can be approved).
i) Review the comments to see if the dates provided coincided with the dates listed on the
ECFbeing worked.
(1) If they do, you will need to add two separate records. One record will be for the
approved timeframe, the other will be for the denied time frame. Ensure the account is
commented thoroughly with the guidance provided. Refer to Section 1.8
(2) If they do not, you will need to comment the DCN in the New Comment section of the
database.
(3) Once a decision is made, the entry will be returned to you in the database. Process the
ECFaccording to the guidance provided. Refer to Section 1.8 Process/Update ECF
Screen.
5) If the employer is listed as an approved not-for-profit organization, review the date in which the
employer was approved.
a) If the approved date is within one year from the date the new ECFis received, approve the ECF
based on the current approval in the database.
b) If the approved date was greater than one year from the date the new ECFis received, follow
the steps below.
=1--~1
5
i) Populate the ~rb=)( through l(b)(6) Ito have the employer reviewed to ensure they have
maintained their not-for-profit status with the IRS.

OF INFORMATION ACT
ii) The fbJ(Bl lwill be worked by one of the PSLFLeads to verify the employer still has their
not-for-profit status.
iii) If the employer still qualifies, the Lead will update the approved date in the database and
you may proceed with processing the ECF.
iv) If the employer is no longer approved, the Lead will update the database to reflect the
employer is denied, update the ECFrecord on [filfil[Jto reflect a denied status, and have the
borrower contacted.
v) Once a decision is made, the entry will be returned to you in the database. Process the ECF
according to the guidance provided. Refer to Section 1.8 Process/Update ECFScreen.
)
- ,- ,-,, ''Jr'F Of ,.,.," "'FF,l'•'" .,r W•'l'I -nwn.F
.3 '.: ,C,C fC Jl.:•O', H eSI.C•ll'SOfl"CCl j i,SSS E"CC
,:,F•S''llCHOti ·:;.; ,, , • C,:,fS',HOti 'OUt,: r,:,t, ,J,:, C''l t,c,-
• t1r 1 •, ·« 11>"l'F''
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6) If an exact employer match is not found in the Employer Database, determine if the organization is
affiliated with religion.
(1) Review Section 3 of the ECFto see if website is listed.
(a) If provided, place the website into the address bar and press enter. Continue to
step (3).
....
File Edit
ww;,,gccgle.con,
V1ev, Fa ✓ ontes Tools Help
(b) If the website is not listed on the ECF,open Windows Explorer and perform a
Google search for the organization's name.
(2) Click on the organization's website.
(3) View the pages for religious content under "About Us" and "Our Mission" sections to
determine if the employer is affiliated with religion.
(a) If the organization is affiliated with religion, processing of ECFrequest will be based
on the version of the ECFwas received. See the examples below.
(b) Below is the oldest version of the ECF.The *Note at the bottom states the religious
organization only qualifies if the borrower's job duties are unrelated to religious

OF INFORMATION ACT
instruction, worship services, or proselytizing. In addition, the date format for the
"Dates of Employment" field is listed as DD/MM/YYYY .
(:, , ,t .. , 1 ,., "' ,·,w • '.' ,r• ____J ____J

[,_: '·'',1 .,-,·y,:
'"
-, '' t
''
(c) Below is the ECFwith the expiration date of 11/30/2014. The *Note at the bottom
was modified to indicate that the full-time requirement for borrowers employed at
501(c)(3) and private non-profit organizations cannot include time spent on job
duties that are related to religious instruction, worship services, or any form of
proselytizing. In addition, the date format for the "Dates of Employment" field was
changed to MM/DD/YYYY,
(" I l ,,-,,.-_-, c,, ,----n ;-· ,., • cr•·-n t

C:: p1,,_,,,,yy-,Y:>
"'
(d) Below is the ECFwith the expiration date of 12/31/2017. It is explained in question
8, that the average number of hours per week field should not include any hours
spent on religious instruction, worship services, or proselytizing.

OF INFORMATION ACT
SECTION 3: EMPLOYMENT INFORMATION (TO BE COMPLETED BY THE BORROWER OR EMPLOYER)
1. Employer Nanw: 10. 11your employ,,, J ta, exempt orf(JllilJtion under

'>t'di(m 50l(c)(31 of lhf' lnl<'rn,,I RH'<'mie Code I
,. F.-d.-r<1IErnploy.-r ld.-ntif1(<1l1on Nurnbt'r (EIN): OYt'<, - \kip !O Sntion 4

ONo-Continut'toltt'm ll
-- -------
Your ,•mp!oy<'r''> FIN m<1ybt' found on your Wagt' <1r1d 11. h your t'lllploy .. , d not-for-profit org.;nildtion'
1<1~<.t<1tenwnt IW-2). Dvf's - (ontirrne to lten, 11
,. Employer Addre,,. □ No Yor1r employ,,, doc, not qu3J1fy.
11. Is yo1n employ .. , d pdrt,~,rn polit,cdl o,gani;Jt,on 1
OYes - Your employer does not qualify_
lmployer Webs,te (it ,my)
'· ONo - Continue to Item 13.
13. h your ,•mployer d l<1borunion/
5. Employm,·rll B,•gin Datt>: Ov,-, Your t·mploy,•r dOt''> not qual,ty.
-- -- ---- ONo - Continue to Item 14.
,. Er11ploymer1t Erid D<1te. 14. Dot'< you, t'lnployer pro,..id.- <1nyof tlw lwkw,
OR ,ervina,,)
-- -- ----
□ Still t'lllploy,-,cl. OYt''> - St'l<'(t all tht> '>t'l\·itt''> your <'n>ployt'r
,. Employmelll <.talus: nfull-T,men Part-Time pro,•,des and then rnntrnue to Sect,on 4.
~
MOUrs n•r wee, I,werJgei:

ln(lude V,lCJtIon. lr.;ve tmw, or Jny lbln· !Jh n 1mder
..'"...
• tmerp;ency mJn,1p;, ment
0
Mili!Jry s,•rvice lsce <,eo,on 6]
..'"
0
Publ,c >af.-ty
the FJrrnly Med,cal Leaw Act of 1993 If your
law ,·nfm, t'rllt'nt {s.•.- <,,.,!ion 6)
,.rnploy .. , i, ,, SOI(, )13) m d not-for-p,of,t
org,rni1atior1. do no! inrlud,· any hours you ,Iwn! on '"
• '"
Public intt'rt'st lt'gal st'rvilt'' i',t't' Sntion 6)
EJdy childhood edtJ(,i!•on bee dthnit1on of
religious instruction, worship services, or ..
7pllblic st-r,,·,ce orgJni1Jt1on ,n <,eo10n ti)
oroselvti11nl!C
• ~ Publ,c >ervice for indi1·1dc,alsw1!h disabil1t1es
9. Is your <'mployc•r d governmental orgaruza110n' • f'ubl,c sc•rvicc•tor tilt' c•lderly
A go1 ernmc·ntal organization is a Fed,•ral. ',tate. local. • Public h.-<1lth (lt't' ddin,tion of "public ,,.r\•iuc
or lrib,,I govt:rnnwnt org.;nizJtoon. Jgency. c>rt'ntity. J org~nil~tion .. in <,.,(!Fon 6)
public child or famdy wrvicc· Jgt-ncy. a Trib,il coll,•gt· • ~ Pcbl" e<lc,,,<ic,,
or uni1,'t'r<;ity, or Ow Pt'd<t' Corps or Anwri(orps. • Publ,c library 1ervrces
• ',chool librJry services
Dy.,, - ',kip tn <,.,(tion 4
• 0tlwr schoo!-bJsecl ,en;i{e<,
D No - ( ontinut" to llt'm 10.
ONo - YoLJrt'lllploy~, do.-', riot qualdy.
(e) If the employer is affiliated with religion and the borrower submitted an oldest
version of the ECF(DD/MM/YYYY), check if the employer qualifies as 501(c)(3).
(i) If the employer qualifies as 501(c)(3), the request must be denied to advise the
borrower to send in a new ECF.
1. Place a 'Y' in the Bypass letter field
2. Send the "Denied Employed by Religious Org" manual denial letter. This
letter is located in Knowledge Base. See Section 1.8 Process/Update ECF
Screen, step 7).
(ii) If you are unable to determine if the employer qualifies as 501(c)(3), add the
employer to the Employer Database for Supervisor/Compliance/Federal Student
Aid (FSA) review.
1. If it is determined that the employer does not qualify, deny the ECFin the
system as employer not approved.

OF INFORMATION ACT
2. If it is determined that the employer qualifies, deny the ECFusing the same
method as if denying based on the religion related employer qualifying as a
not-for-profit.
(fl If the employer is affiliated with religion and the borrower submitted a newer
version of the ECF(MM/DD/YYYY) check if the employer qualifies as 501(c)(3),
follow Step 0 above.
(i) If the employer qualifies as 501(c)(3), approve the ECF.
(ii) If unable to determine if the religion-related employer qualifies as 501(c)(3),
add the employer to the Employer Database for Supervisor review.
1. If a Supervisor determines the employer qualifies as a not-for-profit,
approve the ECF.
2. If a Supervisor is unable to determine if the organization qualifies, it will be
forwarded to Compliance for additional review.
13) If it is determined that the employer is not affiliated with religion, review to see what type of
public service box is checked and begin your search with one of the corresponding websites for
that type of public service.
14) If no box is checked or the incorrect box is checked, using the resources below try to determine
the correct type of public service.
For government organizations:
1. Access www.usa.gov/agencies for Federal, State, Local or Tribal government organizations,
agencies, or entities.
Select the appropriate link ("State Government," "Local Government" or "Tribal
Government") to access the website for each state, local or tribal.
a) State government.
i. Click state from the list.
ii. Locate the department in which the agency would be located.
iii. Perform a search for the address of the agency.
iv. If the name of the agency and address match, the organization can be
approved with "GO" code.
b) If unable to locate the employer, perform a Google search for the organizations
website. If the domain for the government organization, agency, or entity is .gov or
.mil, then the employer is approved. The following are approved:
i. Public Schools
ii. Public School Districts
iii. Public Libraries
iv. Military Branch (Army, Navy, Air Force, Marines, Coast Guard, State National
Guard)
c) When reviewing an employer that may be government, it cannot be approved just
because it appears on a state website. The employer would need to be organized
under statute or be a political subdivision, etc. in order to be approved under
government. If you are not certain, add the organization to the Employer Database for
further review.

OF INFORMATION ACT
Note: Employers listed on government websites that are typically not governmental entities are
nursing homes and daycare centers. Nursing homes and daycare centers often appear on a state
website because they are licensed by the state, not because they are governmental organizations. In
many instances, daycare centers and nursing homes are for-profit and not governmental.
2. Access National Center for Education Statistics website: http://nces.ed.gov/globallocator/to

confirm public schools, universities, and school districts, libraries.
a) Perform a search using the school information on the ECF.
b) If the name of the school is listed, click on the name of the school to review the details.
c) If the school is listed as a private non-profit, do not approve as government. Proceed
to review the organization as a non-profit 501(c)(3) using the IRS Business Master File
(BMF). See section b) iv) below.
d) All Charter Schools must be reviewed by Compliance for approval.
i. If the School Directory search indicates the school type is "Charter", add the
employer to the Employer Database for further review.
3. Access http://nces.ed.gov/g1oba11ocator/to confirm a Tribal college or university.
4. Add the employer to the Employer Database to be further reviewed if the above resources
are unable to confirm an employer qualifies for PSLFeligibility.
Note: Although the U.S. Congress (U.S. Senate or House of Representatives) qualifies as a government
organization, members of the U.S. Congress (Senator or Representative) do not qualify for PSLF.
Congressional staff members and state legislators (and their staff) may qualify, except for any period
of time that they work for a political campaign, (For that timeframe, the staffer ceases to be a
government employee and is considered to be working on behalf of a partisan political organization.)
5. Email the account information if an ECFfor an employer affiliated with the U.S. Congress is
received to the "FLS PSLFSupervisor Review" mailbox for further review. Place the task on
hold until guidance is provided.
For non-profit 50l{c){3) organizations:

1. Access the Internal Revenue Service (IRS) Exempt Organizations Select Check
2. Search the IRSwebsite (http://www.irs.gov/app/pub-78/) to see if it is listed as having
501(c)(3) status.
3. Search using the Organization's EIN.
a. Any entity that is registered with the IRSas a public not-for-profit organization qualifies
if the Deductibility Status code is listed as "PC" (image below).

OF INFORMATION ACT
Exempt Org3n1z.:mons SeJe<t Check
Tee fcl c., n<;;,:· ,-, c:oe- ·a, -e•e.,,~: o·gar:ar or- tea· a,e e ') Oe :o •ecew ,a, ~•d-C1 Oe co-t· b,i: ons C<c, OS "M Ue~"'· ,r ,-, 51alus
co ·"~r 'o• a o· o a 0a, O" 011.-r1>1O"'. cot••• aec.,.:, r, ,t, cf ,o•t• o,., ors 01aee ,~ C Ho•,,e,•,~ec o• •a, ~-•--r,;,o•,1,-,
0 0._,,. en·,
Re·.,I'.. a,e .o·:e•C S, Er, To co•: ·e,"1c C, a-o:he, ,:J:090·, cl,c• o- :ne ,:o•· •·e•' lc :"e CO,a'l"O~O,ld,-·J •o· .,.,. ca·e,cr, Cl,. S', or[•·••
,,o-, a ·.eco-c :,re·.-. 1,e.-e•,e :re ,o·• or¢e< L·,.· O" a coo·"" oea~n; 10•a" e,o,aoat,o" o, "'or,•a:,o-- " ..,,, ,c:,.-, 0
1 1 of 1 re<1111<
·-• -- (Do1n9 Business As)•

:0 .l-/.:V5J07 Sa•·,,: on;.,,.,, Se,..,,,., n.;
Return 10 Search
b. If the organization is not located by searching with the EIN, search with the name of the
organization.
4. If the organization is not found producing a "PC" Deductibility status, proceed with
verifying the organization is not in a revoked status by selecting the 'Were automatically
revoked' radio button.
11. ,:
----- I•
A.II •
Un1t1=-d
StJtE-s •
""
_:[, ,·,.,
a. Enter the organizations EIN into the EIN field and press search.
b. If a result is found, please place the organization into the PSLFEmployer Database.
i. Comment on the entry that the organization has a revoked status.
5. If the organization is not found with a revoked status, proceed with verifying the
organization by accessing the following IRSwebsite to download the IRS BMF at:
https://www.irs.gov/Cha rities-&-Non-Profits.
a. Select the BMF for the applicable state in which the organization is located. Once the
spreadsheet is open, search (Control F) using the EIN to perform the search.
Note: if an organization has multiple locations across several states, you may need to download the
BMF for the state where the corporate office is located.

OF INFORMATION
I 43 ACT
b. The EIN, name, and the location of the employer must match.
c. To verify that it is a 501(c)(3) organization, the subsection code must be "3." The
subsection code is listed in column I.
d. If the Organization's Name provided matches the name listed in column B, and the
subsection code is "3," the organization is approved.
e. If the Organization's Name does not match with what is listed on the IRSwebsite for
the provided EIN, add the employer to the Employer Database for escalated review.
f. If you cannot locate the organization using any of the Non Profit websites, proceed to
private, non-profit organizations providing public services.
6. If during the escalated review process an issue is identified, you will be notified to contact
the employer to confirm the EIN.
For private, not-for-profit organizations providing public services:

1) Perform one final review to ensure that the organization cannot be approved as
government or 501(c)(3).
i) If unable to confirm if employer is eligible under government or 501(c)(3), add the
employer to the Employer Database for further review for by Compliance.
ii) If the employer qualifies as 501(c)(3), approve the ECF.
Note: Any ECFthat indicates employment with an American Civil Liberties Union-related organization
(e.g. foundation, union fund, ACLU of VT, etc.) must be placed in the employer database for review by
our Compliance department.
15) Escalating non-approved (not listed) employers to Supervisor/Compliance/ FSAfor review:

i) Add t.he em~loyer to the Employer Database
the directories above and then place the ECFI
:l~nizatio~ in one of
See Section 1.7 ECF
~!1~br:~'.:
::1::a::
t:e
Under Review) and comment the account (See Section 1.10 Commenting).Select "Add New
l(b)(6)
- PED~rnc,ss;:.;:1ATES
-
-
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--
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OF INFORMATION ACT
ii) Use ECFform to enter the fields below in pop-up window:

(1) Select your PH# from the drop down box.
(2) SSN
(3) Public Service Organization
(4) EIN
(5) Website Address (If provided or located)
(6) City
(7) State
(8) Comment section Include details regarding the reason for review.
iii) Select "Save Changes."
a) Check Employer Dataase daily to process completed reviews.
i) Open Employer Database.
ii) Click "Review Pending/Hold".
l(b)(6) I
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iii) Work all entries in a "P" status in the ECFstatus column next to the corresponding P or PH
number.
iv) Select the "View Detail" button on the employer entry
v) View the 'Comment History' to determine what action(s) need to be taken.
vi) All records that have not been completed display with the processor's name. The status of
the record will be displayed in the "Status" column. A record under review will reflect one
of the following statuses:

OF INFORMATION ACT
STATUS ECFSTATUS
Approved, Approved Religious, Denied, Inconclusive Pending
Review Hold
(1) Process all records that are "pending," which means the employer has been approved
or denied See Section 1.8 Process/Process/Update ECF Screen.
(2) Select the Make Edits button at the top right.
(3) Change the "ECF Status" from "pending" to "completed" by selecting "completed" in
"ECF Status" dropdown box in the Employer Database, once the record has been added
toTL2U.
(4) Select the current date (todays date) from the calendar drop down box.
(5) Select "Save", to keep the edits made to the record.
Note: ECFswith a "completed" status will no longer appear when "Review My Entries" is selected.
Note: A record that is on "hold" is still under review.
P5LfDci,dV,ew
Make Ed,, I
Delete Recocd I
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1.7 ECF Under Review

1) If it is determined that the ECFrequires further review, follow the below steps.
a) Enter reason for review and your PH number in the Doc Comments field in File Net Imaging.
b) Place the ECFinto a "Review" status on~ (see Section 1.8, Process/Update ECFScreen).
i) Enter an "R" in the "Hold/Review" field on~
ii) Enter all the information intoO
iii) Press F6 to accept the entry.

OF INFORMATION ACT
Note: The system will send a letter to the borrower advising FLSis currently reviewing their eligibility
for PSLF.The letter will advise that we will be in contact with them once the review is completed. The
status of the form will reflect "Review"
c) Add the employer to the database for review.
2) Complete request based on outcome of Supervisor/Compliance/FSA review in the database.
a) Access the Image from the Review Queue:
i) Select "Workflow" from the first drop down menu.
ii) Select "FLS Servicing Review" from the second drop down menu.
iii) Enter the SSN in the 'Account Number or SSN' field.
iv) Select Search.
v) Select "View Item" on the first line.
b) Approved by a Supervisor/Compliance/FSA:
i) Comment TL2U with the details of the determination and that approval was provided by
Supervisor/Compliance/FSA (see Section 1.8, Process/Update ECFScreen).
ii) Approve the employer. See Section 1.8, Process/Update ECFScreen.
Note: The system will generate the approval letter to the borrower.
c) If Compliance or FSAdenied ECF:
i) Comment TL2U with the details of the determination and that Compliance/FSA provided a
denial. See Section 1.8, Process/Update ECFScreen.
ii) Update the current~record.
(1) Change the Hold/Review field from "R" to 'N' and deny the employer. See Section 1.8,
Note: The system will generate the denial letter with the reason that the employer does not qualify.
1.8 Process/Update ECF Screen
1) Access the PSLFScreen~in COMPASS'M.

a) Enter the borrowerrrsNTound on the ECF.
b) Enter X in Employment Record to select option.
c) Press ENTER.
Note: Employment data will display only if the borrower previously submitted an ECF.
Note: Selection screen displays if the borrower submitted more than one ECF.If the borrower only
has one ECFon file, COMPASS'Mproceeds directly into the ECF.
2) Review the PSLFEmployment Section Screen LJ·

OF INFORMATION ACT
ITL?U FEDERAL VTAM KEQO TLX?l·J

DATE 02/25/ 14 12:00:00 PUBLIC SERVICE LOAN FORGIVENESS EMPLOYMENT SELECTION
BORROMEA SSN: NAME: PAGE 1 OF
FORM EMPLOYER EIN: BEGIN END HOURS/ FOAM

NUM NAME DATE DATE l·JEEK STATUS
1 1
---------------
__ , __ /_
2 2 _/_i_
_/_/_
3
4 "
4 _/_/_ ---
i
s s _/_ - ---
i
6 6 -- --
i-
SELECTION
F1 HELP F3 EXIT F5 AFR F7 BKl·ID F8 nm F9 PAT F12 CAN
a) This screen displays the following data:

i) Form Sequence
ii) Employer Name
iii) EIN
iv) Begin Date
v) End Date
vi) Hours/Week
vii) Form Status
b) If the ECFcontains data that matches what is already on the COMPASS'Msystem:
i) Verify the data on the ECFis the same as the record on ITL2U.
(1) Select the employment record by typing number associated with the record in
SELECTIONfield.
(2) Press ENTER.
ii) If data on the ECFis the same as the record on ITL2U, proceed to commenting the account.
The comment must include:
(1) The date the ECFwas received.
(2) The DCN.
(3) State duplicate ECFwas received and that no adjustment is necessary.
c) If the ECFcontains new data, add the ECFto the system.
i) Change the indicator to 'A'
ii) Press ENTER.This will take you to ATL2U to add the borrower's employment data.

OF INFORMATION ACT
3) Review the PSLFEmployment Screen.
/!i:!TL? U 1 ;> :M ',ti ,'Bq : VTAM KIUti TLX?X

DATE 0',/?',/1? 1,:an::M
BORROWER SSll: 1;,:, ,)', 1;,'"\' DOB:
NAME: .JOHN P DOE
ADDRESS: 1?00 II ?TH ST ADTL REVIEW· N
ADDRESS: BYPASS LTR; U
ADDRESS: ----------------~= ELIGIBLE LOAtJS:
CITY: HARRISBURG STATE: PA ZIP CODE: 1,'10;,'
FOil ST: FOil CD: FON CUY:
DOM HME PHFI: AC I' 1 I' EXCH '>'>'> LCL '>'>'>'> DOM ALT PHU: AC EXCH LCL
FGtA PHIJ: CtlY CTY LCL
EMAIL:
BORROWER SIGNED: DATE SIGNED:
Eltl: EMPLOYER tlAME:
EMPLOYMEflT BEGitJ DATE: EMPLOYMEtlT END DATE:
EMPLOYMErJT STATUS: HOURS PER MEEK:
TYPE OF PUBLIC SERVICE: TYPE OF NON-PROFIT: ADDRESS PRVD:
AUTHORIZED IJAME; DTE SGfJO:
TITLE: SIGNED: ACCEPTABLE:
DOM PHN: AC EXCH LCL EMPLOYER APPROVED:
FGtJ PHN: CPJ Y CTY LCL
EMPLOYER OVERRIDE. U SERVICED AT.
F 1 =HELP F~=EXIT F4=CMTS F'.>=RFR Fl:>=ACPT FU=PAT FI O=PDEM F 1 :,>=CAN
i) Demographics
(1) If the borrower does not have a relationship with FLSyou will need to enter in the
following to ATL2U:
a. Date of Birth
b. Borrower's first name
c. Middle initial if applicable
d. Last name
e. Mailing address including the street, city, state, and zip code
f. Enter any foreign, home or alternate phone numbers
g. Enter borrower's email address if provided
Note: The demographic information auto-populates if the borrower has previously had a relationship
with FLSor the borrower previously submitted an ECF.
4) Formatting - Use proper format when entering information into COM PASS'M.
a) EMPLOYERNAME. Below are two examples of common errors.
i) Enter a space after a colon.
(1) Correct Format- BLOOMSBURG UNIVERSITY: OFFICE OF FINANCIAL AID
(2) Incorrect Format- BLOOMSBURG UNIVERSITY:OFFICEOF FINANCIAL AID
ii) Ensure there is no space before the first letter/number of data in a field. Example:
(1) Correct- NAME MATTHEW
(2) Incorrect - NAME MATTHEW
5) Update all applicable fields. See below for direction on specific fields:
a) REVIEW/HOLD- Field defaults to blank or 'N' (not on hold or in review). Change to 'R' or 'H' if
additional review of a qualifying employer is needed by Compliance/FSA.
i) The ECFwill be placed in an 'R' status if the further guidance/review is needed. This will
send a letter to the borrower advising the ECFis under review and they will be notified
once the review is completed.
ii) The 'H' status should only be used when you have fields on TL2U but are unable to
approved or deny due to an unforeseen circumstance. i.e. Phone call, Emergency, etc.

OF INFORMATION ACT
b) ELIGIBLELOANS- Enter 'Y' or 'N' to indicate if the borrower has Direct Loan(s). Entering "N"
will deny the ECF.
c) CHANGE REASON- Enter 'C' for Correction or 'U' for Update to reflect a change was made to
the ECFrecord.
i) 'C' for Correction should be used when a mistake is made to the original entry.
Example: The end date of employment was entered incorrectly when it was initially
processed. Placing a 'C' in this field prior to making the correction will show a correction
was made to the original entry. Commenting what was corrected is required.
ii) 'U' for Update should be used when an update from the employer needs to be made to the
original entry.
Example: The ECFwas denied for missing EIN. Place a 'U' in this field to process the ECF
based on the provided information. Commenting what was updated is required.
d) EMAIL- Enter email address from ECF.Do not update the contact email address on
COM PASS'Mdemographic file from a form if the borrower is enrolled in email correspondence
(ECORR). To determine if the borrower is on ECORR, review the bottom of~ as shown
below.
e) BORROWERSIGNED- Enter 'Y' or 'N' to indicate the borrower signed the form.
f) DATE SIGNED- Enter the date the borrower signed the form. If the date the form was signed is
missing, use the date received.
g) EIN - Enter the Employer Identification Number (EIN). If no EIN is provided, call the employer.
If unable to obtain EIN, deny the request.
h) EMPLOYERNAME - Enter the employer name. If the name of the organization is missing, call
the employer. If unable to obtain the name, deny the request.
i) EMPLOYMENT BEGIN DATE- Enter the start date provided by the employer. The begin date is
the date on which the borrower began working for the employer.
i) If a new ECFis received that recertifies the borrower's employment, the begin date for the
new ECFentry must be the date after the last certified employment end date.
Example: Record for SSN 123-45-6789
Previously Approved ECF:

Penn State Hospital
Begin Date: 01/01/2010 End Date: 06/30/2014
New ECFreceived reflects:

OF INFORMATION ACT
Penn State Hospital

The following would need to be entered onto ITL2U:

Penn State Hospital
j) If this date is missing, or if the date of employment is in the future, call the employer. If unable
to obtain the begin date, deny the request. This date cannot be in the future.
i) The certification date format on the oldest version of the ECFis DD/MM/YYYY, most
employers enter the dates as M M/DD/YYYY. The most recent version of the ECF(published
November 2014) does not list a date format.
ii) If date is obviously in a MM/DD/YYYY or DD/MM/YYYY format, assume both begin and end
dates are in the same format.
Example: The begin date is listed as 01/31/2010 and end date as 05/10/2013, on a form
that requires DD/MM/YYYY format. Since the date was written in MM/DD/YYYY format,
you should assume both the begin date and end date are in MM/DD/YYYY format. The
begin date would be January 31, 2013 and the end date May 10, 2013.
k) EMPLOYMENT END DATE- Enter the end date provided by the employer. The end date is the
date on which the borrower stopped working for the employer. If the employer provided a
date in the future, the date on which the authorized official signed the form must be used.
i) Form Expiration Date: 12/31/2017 has a "still employed" box. If this box is checked, use
the date the authorized official signed the form as the employment end date.
Employment End Date:

OR
Ostill employed.
Note: Phrases such as, "still employed," "currently employed," or anything similar are acceptable on
the ECFform with an expiration date of 11/30/2014. The date the authorized official signed the form
should be used as the employment end date.
I) EMPLOYMENTSTATUS- Enter either 'F' for full-time, or 'P' for part-time. If the status is
missing, call the employer. If unable to obtain, deny the request.
m) HOURS PERWEEK - Enter a numeric value for the number of hours. Decimal points (Ex: 35.50)
can be entered for partial hours. If the number of hours is missing, call the employer. If unable
to obtain, deny the request.
n) TYPEOF PUBLICSERVICE- Enter one of the following codes:
i) "GA" for Government AmeriCorps,
ii) "GO" for government organization,
iii) "GP" for Government Peace Corps,
iv) "NP" for non-profit 501(c)(3) organization, or
v) "PR" for private, non-profit organization.

OF INFORMATION ACT
o) TYPEOF NON-PROFIT- Enter the applicable code in this field if PR is selected as the type of
organization.
EC EARLYCHILDHOODED
ED PUBLICEDUCATION
EM EMERGENCYMANAGEMENT
LE LAW ENFORCEMENT
MS MILITARY SERVICE
OS OTHER SCHL SERV
PE DISABILITIES/ELDERLY
PH PUBLICHEALTH
Pl PUB INT LAW SERVICES
PL PUB LIBRARYSERV
PS PUBLICSAFETY
SL SCHL LIBRARY SERV
If PR is not selected as the type of organization, leave this field blank.
p) ADDRESSPRVD- Enter 'Y' or 'N' to indicate if the employer provided their address. Only the
city and state are required on the form.
q) AUTHORIZEDNAME - Enter the name of the authorized official. If the name is missing, call the
employer. If unable to obtain, deny the request.
r) DT SGND (date signed)- The date the authorized official signed the form. If the date signed is
missing, deny the request.
s) TITLE- Enter the title of the authorized official. If the title is missing, call the employer. If
unable to obtain, deny the request.
t) SIGNED- Enter 'Y' or 'N' to indicate the authorized official signed the form.
u) ACCEPTABLE- Enter 'Y' or 'N' to indicate if the authorized official is acceptable. This field
should always be populated 'Y' unless the borrower self-certified the ECFor you are directed
by a Supervisor or Compliance.
v) DOM PHN - Enter the employer's domestic phone number. If information is missing, call the
borrower. If unable to obtain, deny the request.
w) EMPLOYERAPPROVED- Enter 'Y' or 'N' to indicate if the employer is an approved public
x) EMPLOYEROVERRIDE-This field will default to 'N' Change to 'Y' if record is being updated
because FSAapproved the employer as a qualifying public service organization.
y) FGN PHN: (Employer Foreign Phone) - Enter the employer's foreign phone number found in
"Authorized Official's Telephone" field in ECF.
z) BYPASSLTR-Field defaults to 'N.' Change to 'Y' in the instance you need to prevent a system
denial letter from being sent. See Section 1.9 Sending A Manual Letter
i) If two part-time forms for the same period are received and processed together that do
not total 30 hours per week, the borrower does not meet the full-time requirement.
(1) Enter 'Y' in the BYPASSLTRfield when entering the employment data for the first part-
time employer prior to pressing F6 to suppress a denial letter from generating.
(2) Enter data from the second part-time employer with 'N' in BYPASSLTRfield and press
F6. A letter is sent to the borrower indicating their ECFis conditionally approved. The

OF INFORMATION ACT
letter will state that although their employer(s) qualify, they must be working full-time
to qualify for PSLF.
aa) SERVICEDAT- Populate this field with the servicer code (below) to ensure borrower's loans
are transferred to FLSfor servicing if the borrower has PSLF-eligible loans with another servicer
(determined in Section 1.3 Review NSLDS).
CODE SERVICER
cs COSTEP
EL EDGEUCATIONLOAN
EM EDMANAGE
FE ED FINANCIAL
FG GLHEC
FH UHEAA
Fl ASPIRE
FM MOH ELA
FN NELNET
FO OSLA
FR GRANITESTATE
FS NAVIENT (formerly Sallie Mae)
FT MONTANA
KS KSASERVICING
ss SPLITSERVICER(MORE THAN ONE DOE SERVICER)
LEAVEBLANK ONLY FEDLOANOR BORROWERHAS0 DIRECTLOANS
Note: If "SS" is entered, FLSwill contact all of the borrower's servicers to request a transfer of their
loans.
aa) PRIORSRV (prior servicer) - Enter 'Y' or 'N' if there has ever been a Prior Servicer, prior to the
current servicer. This field is only required if the ECFis approved and the borrower has loans
with another servicer. To determine if the borrower has a prior servicer:
i) View the Loan Detail for each Direct Loan with a balance.

OF INFORMATION ACT
Sort by: --- Select -

Submit I
Display Only: ----- ALL -----
Currently Sorted by' LOAIJ DATE Mo liltenng
D
D1 . DIRECT STAFFORD SUB
AMERICAN UNIVERSITY . 00143400
Status: RP as of 11/01/2014
I Lmrn Detail
Approved Amt: $8 500 Disbursed Amt: $8.500 El OPB: SB 610 Agg. OPB: $8.500
Loan Date: 08-'16:2010 Sep. Loan Ind: H Loan Period:
Last Disb. Date: 01-'0G:2011 Last Disb. Amt: S4 250 Acad. Lv: A
ED Servicer: DEPT OF EDIFEOLOAI J SERVICII JG,PHEAA' - !',79
D2. DIRECT STAFFORD UNSUB
n AMERICAN UNIVERSITY - 00143400
Status: RP as of 11/01/2014
Loan Detail I
Approved Amt: $12 000 Disbursed Ami: S12 000 El OPB: $13 825 Agg. OPB: S12 000
Loan Date: 08-'16-'2010 Sep. Loan Ind: J Loan Period:
last Dish. Date: 01,'06:2011 last Dish. Amt: S6 000 Acad. Lv: A
ED Servicer: DEPT OF ED1FEOLOAIJ SERVICII JG,PHEA.A· - !',79
n DJ. DIRECT PLUS GRADUATE

AMERICAN UNIVERSITY - 00143400
Status: RP as of 1110112014
Loan Detail
Approved Amt: S15 000 Disbursed Amt: $15 000 □ OPB: S17 507 Agg. OPB: so
loan Date: 08-'16-'2010 Sep. Loan Ind: A Loan Period: 08,23,2010 - 0510312011
Last Dish. Date: 01-'06-'2011 Last Dish. Amt: S7 500 Acad. Lv: A
ED Servicer: CEPT OF EC,FEDLOAl·J SERVICll·IGiPHEM· · 579
01 - DIRECT STAFFORD SUB Status: RP as of 11/01/2014
D AMERICAN UNIVERSITY . 00143400
Loan Detail I
Approved Amt: $8 500 Disbursed Amt: SB 500 El OPB: SB 610 Agg. OPB: SB 500
Loan Date: 08'17-'2009 Sep. Loan Ind: E Loan Period: OB12-112009.0510-112010
Last Dish. Date: 01-'04-'2010 Last Dish. Amt: S-! 250 Acad. Lv: A
ED Servicer: DEPT OF EQ,fEOLOAI-J SERVICll·JGiPHEM· - 579
ii) Review the Guaranty Agency/ Lender/ Servicer Agent History to review if the borrower has
a prior, prior servicer. If the borrower has a prior, prior servicer this field would need to be
populated with a 'Y'.
SU.rt ..
Guaranty Agency I Lender I Servicer Agent History
, Coo•
Servicer Agent
02 14 201c C, 31 2DL c'.-4 L, I ' c [:, -<~·.1·[ . ~ 10
( i:s 1F ?o,c r.; , , ; 01,
iii) If the borrower does not have a prior, prior servicer the field would be populated with a
'N'.

OF INFORMATION ACT
Guaranty Agency I Lender/ Servicer Agent History

Name
Servicer Ageitl
bb) Press F6 to proceed after completing all fields.
6. The Form Status field reflects one of the following four statuses: Approved, Denied, Conditionally
Approved, or Review.
a) Approved (A) -An 'A' in the Form Status Field indicates that the ECFis approved and an
approval letter is generated.
b) Denied (D)-A 'D' in the Form Status Field indicates that the ECFis not approved and a denial
letter is generated.
i) The reason(s) the borrower does not qualify is listed.
ii) The missing information is listed and the letter will explain the steps for the borrower to
have the ECFreconsidered if information was missing.
iii) See Step 1.9 below for manual denial letter instructions.
iv) The system-generated denial reasons are listed below:
a. Full Name
b. Date of Birth
C. Borrower Signature
d. Employer Name
e. Employer ID Number (EIN)
f. Employer Mailing Address
g. Employment Begin Date
h. Employment End Date
i. Employment Begin/End Dates Not Valid
j. Employment Status
k. Average Hours Per Week
I. Authorized Official's Name
m. Authorized Official's Title
n. Authorized Official Signature

o. Authorized Official's Telephone Number
p. Date Authorized Official Signed Form

q. Official Not Eligible to Certify
r. Public Service Organization Not Approved
s. No Eligible Loan Type(s)

OF INFORMATION ACT
c) Conditionally Approved (C) - A 'C' in the Form Status Field indicates that the EFCis approved,
but their hours are listed as part-time. A letter is generated advising the borrower that
although their employer qualifies, this employment period cannot be used to match qualifying
payments because they are not employed full-time. To have this period qualify for PSLF,the
borrower must provide another ECFcertifying another PSLF-qualifying part-time position that
overlaps the same period, provided the total hours of employment is at least 30 hours per
week.
d) Review (R)-An 'R' in the Form Status Field indicates that the employer's information needs to
be reviewed further by a Supervisor, Compliance or FSA. Place the task on hold until the
review is complete. A letter is generated informing the borrower that their eligibility for PSLFis
under review at this time and they will be notified when a determination is made. After FSA
reviews employer's eligibility, the process continues and the Form Status field will be changed
toA,D,orC.
1.9 Sending A Manual Letter

1) Send a manual denial letter.
a) To deny a request for a reason not included in the system-generated denials,
i) Enter 'Y' in the BYPASSLTRfield.
ii) Locate letter in Knowledge Base.
iii) Send a manual denial letter when you encounter the following scenarios:
(1) Illegible fax - If the borrower's ECFis illegible and you are unable to determine the
information on page 2 of the form
(a) Send the "Illegible Fax- ECFReceived Letter" manual denial letter.
(2) All loans defaulted - If the borrower's Direct Loans show as defaulted on NSLDS,deny
the request through the system for the reason that the borrower's loans do not qualify.
(a) Send the "Denied Defaulted Loans" manual denial letter.
(3) Submitted invalid ECF- If the form is not OM B approved, deny through the system for
the reasons that the ECFwas not signed by the borrower and employer. Place an 'N' in
the borrower signed and employer signed fields.
(a) Send the "Denied - Invalid ECFNot 0MB Approved" manual denial letter.
(4) If the new form with an expiration date of 12/31/2017 is received and box 15 in section
4 is not checked, we are unable to approve the request. The employer must check this
box to indicate that the information in Section 3 is true/complete.
(a) Send the "Denied - Box 15 Not Checked" manual denial letter.
(5) If the borrower was denied for not having Direct Loans, consolidated their ineligible
loans into a Direct Consolidation Loan and submitted the same form that was
previously denied for not having Direct Loans
(a) Send the "Consolidated - New ECFRequired" manual denial letter.
(6) Employed by a religious organization - If the employer is affiliated with religion and the
borrower submitted an older version of the ECF(DD/MM/YYYY), check if the employer
qualifies as non-profit.
(a) If the employer qualifies as non-profit, leave the hours per week field blank
(b) Send the "Denied Employed by Religious Org" manual denial letter.

OF INFORMATION ACT
(7) Attached certification - If the ECFis not completed and the employer attached the
certification
(a) Send the "Attached Certification-Action Required" manual denial letter.
(8) If the organization is still operational, and the box on the form is checked indicating
unable to obtain certification
(a) Send the "Incomplete or Missing Certification" manual denial letter.
(9) Cannot obtain certification - If the box is checked indicating the organization is closed
or is refusing to certify employment
(a) Refer to Section 1.6, step 15) for instruction
(i) On the old form with an expiration date of 11/30/2014, the box is located in
Section 3.
(ii) On the new form with an expiration date of 12/31/2017, the box is located in
Section 2.
(b) Additionally, if the borrower or employer requests FLSto obtain employment
certification from another source (such as a website), this request must be denied.
(c) Send the "Unable to Obtain Certification-Action Required" manual denial letter.
(10) Employment Certification Prior to 10/1/2007- If the ECFis certified with the entire
public service employment period prior to the start of the PSLFProgram (10/1/2007)
(a) Send the "Employment Certification Prior to 10/01/2007" manual denial letter.
(11) Borrower not employed - If the employer indicates the borrower is not employed
(Example: indicates borrower is not a paid employee, is a volunteer, a contractor, etc.)
(a) Send the "Denied Not Employed by Public Service Org" manual denial letter.
Open the letter template that is needed for the borrower. Once the template is opened, enter
today's date at the top of the letter
a) The format must be MONTH DD, YYYY
i) The month must be fully spelled out and in all capital letters.
ii) The day must be two digits.
iii) The year must be four digits.
iv) A comma must be between the day and the year.
EXAMPLE-
JANUARY 01, 2015
flR'.'T NAM[ LASTNAM[

ADDRESS 1
b) Enter the borrower's name as it is displayed on~ If it is not a FLSborrower use the name
displayed on~.
i) The borrower's name must be in all capital letters.
ii) If a middle initial is listed for the borrower it must be used on the letter.

OF INFORMATION ACT
c) Enter the borrower's address as it is displayed on~. If it is not a FLSborrower use the
name displayed on~ LJ
i) The entire address must be capitalized.
ii) If the suite number or apartment number DOESfit on the same line as the delivery
address, you must put the suite or apartment number AFTERthe deliver address.
EXAMPLE- JANE A DOE
2 MAIN ST APT 2
HARRISBURG PA 17106-9184
iii) If the suite or apartment number DOES NOT fit on the same line as the delivery
address, you must put it on the line ABOVE the delivery address.
EXAMPLE- JANE A DOE
APT 12
1234 MARTIN LUTHER KING JR BLVD
iv) No punctuation.
v) If the full 9 digit zip code is listed, it must be used in the letter. It is acceptable to place
a hyphen in the zip code.
d) Review the letter to ensure that no field within the body needs completed. Some letters
require you to enter additional information such as an employer name or dates of
employment.
e) Once the letter is completed, save it in the 'PSLF LETTERQA' folder stored in the Z drive.
5
(Location: fbl( l lpslf letter qa)
Note: You can view the !Connect article on How to Map the Z Drive for assistance.
To save the letter:
i) File-> Save As
lnoert Pag,
_d Save
Infer
,;1,_Save As
ii) Select the Z Drive OR input (bJ(6J

OF INFORMATION ACT
Fa>.crites
!!: De,ktcp
~- Dce,nload,
Re<ent Places
L,brariec
· Dccumento
~ 1,lusic
.._ P,,tcir~,
B v,deoc
b)(6)
iii) (Z: drive users) Select the PSLFLETTERQA folder

b)(6)
(b)(6)
iv) Save the document as First lnitIa, as
':, fedloan_opJerat1onsLJ (Z:)
File name: IJSmith_07302015_123456789
Save as type: Word Document
f) A QA representative will review the letter and ensure that it meets all guidelines.
a. If errors are found, the QA representative will correct the errors. Once the letter is
correct, the QA rep will image, print and mail the letter to the borrower. You will be
alerted of the error via the QA database.
b. If no errors are found the QA will image, print and mail the letter to the borrower.
1.10 Process RVECF

The RVECF(PSLFREVIEWECF)ARC is populated by processors or PSLFphone representatives when an
existing ECFentry or previously processed ECFneeds to be reviewed.
1) Review the request and make any necessary adjustments.

OF INFORMATION ACT
i. Review the indicated record along with ECFdocument and any additional information on
file.
ii. If the request to update the record with missing information received
iii. Review to see if the ECFcan be processed.
1. If all missing information is received, update the record with the information.
2. If we are still missing information that can be obtained via phone call, call the
employer to try to obtain the missing information.
iv. Comment the task on TD2A with the adjustment that were made. See Section 1.10
commenting.
1.11 Commenting
1) Comment on fbl(5l I
a) Press F4 from the Employment Processing Screen in ~to comment.
b) An 'X' will automatically populate in the FORM field and the ECFsequence number will
automatically be populated in the FORM SEQfield. If you do not wish to comment under a
specific form you may select the option to comment under General.
COMMENTDISPLAYCRITERIA:
ALL:
GENERAL:
FORM: FORMSEQ:
SORT NE~JEST
TO OLDEST:
SORTOLDESTTO NEHEST:
c) Press ENTER.
d) Press the Home key to place cursor to the top left of screen.
e) Change the 'I' to a 'C' (CTL2U).
I) Press ENTER.
FEDERAL VTAM KGBO TLX35

DATE 11/06,13 14:18·44 PUBLIC SERVICE LOAN FORGIVENESS EMPLOYMENT COMMENTS
BORRm•JFR SSN NAMF ·
FORII SEQ. FORM STATUS. A

EIN: 221821292 EMPLOYER NAME. ESSEX COUNTY COLLEGE
EMPLOYMENT BEGIN DATE· 11/16/2011 EMPLOYMENT END DATE· 07/12/2012
DATE: 08/15/2012
COMMENTS:
PH2028') 08'15/2012 ECF APPROVED LETTER SENT TO BORROL·IER
g) Reason for commenting:

OF INFORMATION ACT
i) Outbound calls- comment should begin with your P or PH and date of comment. All details
of the call attempts and or conversations must be thoroughly documented as well.
• Example: PH12345 01/01/2015- CALLED EMPLOYER, LEFT MESSAGE FOR AUTH OFFCL
JANE DOE DUE TO MISSING EIN. ADVSD HRS OF OFFC & PHN #TO CLL BCK.
ii) Additional review - If an ECFis being placed under Review status, comment the details as
to what is being reviewed.
• Example: PH12345 01/01/2015- EMPLYR PLCD INTO DB FOR ADDTNL RVW.
iii) Manual letter - Anytime a manual letter is sent, comment why the letter was sent.
• Example: PH12345 01/01/2015-SNT MNL LTTR TO BRWR ADVSNG BOX 15 NOT CHCKD.
2) PSCOM-This will need to ~d if we do not have an SSNfor the borrower at the time of the
call AND we do not have a~record OR an account on COMPASS'M.
a. Complete the following fields of the PSCOM:
i. Rep Name
ii. PH#- If you do not have a PH# use your P#
iii. Borrower Name
iv. SSN (Use the one that was obtained)
v. Reason for Call
1. Complete the Additional Comments Section
b. Once all needed fields have been completed, archive the image. See Section 1.10
Archive Image.

OF INFORMATION ACT
□ Inbound Call □ Outbound Call
Rep Name
PH#
Borrower Name
SSN
Date of Birth
Borrower's Address
Borrower's Phone#
Reason For Call:
□ Ad,.,Isedmust maf.e 120 quallfymg pa,ments

□ Ad',·Isedpayments must be receI1·edwi1hIn30 days pnor or no later than 15 days after
Payments
the due date
□ Ad•,·1sedpaymentsdo not ha•,eto be consecub'.•e
□ Ad·.'ISedto submit ECF annuall',1
□ .Ad1·Isedto OOwnloadform from website
□ Borrower requestedfonn bJ'mail
□ Borrower requested form by email
ECF
□ Ad•,·IsedECF rece1·,edbut not processed yet
□ Ad•.'1sedprocessing lime once ECF is received
□ Ad•,·Isedto submit new ECF if Change In employer
□ Ad•.'1sedfor--prof1I
organ1.:at1ons
do not qual1f1 for PSLF
1
□ .Ad1·Isedto appr/for an IDR plan

□ Ga•1eborrower estimateon IDR
Repayment
Schedule □ Ad•,·1sedstandard repayment sdled..ile not beneficial
□ .Ad,.,1sedgraduated & extended repa:ments do not rµalt:,c
□ .Ad,,·1sedonl:, IDR schedules are beneficial to program
□ Ad',·1sedto consolidate FFEL Loans to be(l)me Direct Loans

□ .Ad,.,1sedwt7en consol1dating to not include D 1rectLoans t already made rµalt:,cing PSLF
payments
Consolidation
□ .Advised no eligible loans per nsLOS. will need to consolidate
□ .Ad1•1sedall loans eligible for PSLF as the:' are all DL's no need to consolidate
□ Ad',·1sedto submit ECF once omsolidatron 1scompleted
Organization Name:
Employer
Information Organization Address:
(If contact with
Organization Phone#:
employer was
made) Representatives Name:
Dates of Employment:
Additional
Comments:

OF INFORMATION ACT
1.12 Archive Image

1) Archiving PSCOM Document
2) ■
Double click Send to Imaging Icon on your desk .
.
..
3) If you do not have this application on your desktop
a) Open v:\ENT_Shortcuts in My Computer
b) Copy Send to Imaging icon to the desktop.
Aildre" I _J V:\ENT Shortell,
Size ;,,,
_ b)(6) Frie Folder
,-
1
,_ Frie Folder
Frie Folder
,_ r,lc Colder
,_ Frie Folder
,_ Frie Folder
Frie Folder
1-
,- Frie Folder
,- F,lc Folder
Frie Folder
l~--~------J,K8 Shortcc'
g&Send to Imaging 1 KB Shortcct
12ob1ects
4) Drag the PSCOM document you wish to archive to the "Drop File Here" icon.
5) Complete the attribute fields applicable.

a) SSN
b) DOC ID
c) ARC
Set Attributes
P=c,,durz,f Updal@ r,,sts Ink

OF INFORMATION
I 63 ACT
6) Select OK to archive the document.

7) After document is archived, delete document from your desktop.
FileNet Imaging
When processing is completed, select Workflow Complete under Document Commands to archive the
document.
DOCUMEIH COMMAIIDS
WortdlowComplete I►

OF INFORMATION ACT
Prerequisite Documents
Knowledge Base ATC00 -Automated Calling Process (ACP) User Guide
Content Connection COMPASS'MNavigation
Related Documents
Knowledge Base NSLDSTraining Overview
Customer Service Procedures: FileNet Imaging
Student Aid PSLFQ&A Document
Related Letters
Letter ID Description
FS06BECFDN ECF Denial Letter
FN06BECFDN ECF Denial Letter- Non Fed loan Servicing Borrower
FS06BECFAP ECF Approval Letter
FN06BECFAP ECF Approval Letter - Non Fed loan Servicing Borrower
Knowledge Base Illegible Fax - ECF Received
Knowledge Base Defaulted Loans Denial
Knowledge Base Denied - Invalid ECF Not 0MB A(:!(:!roved
Knowledge Base Denied - Box 15 Not Checked
Knowledge Base Consolidated- New ECF Reguired
Knowledge Base Denied Em12loyed by Religious Org
Knowledge Base Attached Certification-Action Reguired
Knowledge Base lncomtJlete or Missing Certification
Knowledge Base Unable to Obtain Certification - Action Reguired

OF INFORMATION ACT
Knowledge Base Em~loyment Certification Prior to 10L01L2007
Knowledge Base Denied Not an Em~loyee of Public Service Org Listed
Knowledge Base Digital Signature- Borrower
Knowledge Base Digital Signature- Em~loyer
Knowledge Base Digital Signature- Borrower & Em~loyer
Knowledge Base Employment Prior to Disbursement of Loan
Related Technologies/Reports
Screens
Screen Name System Mode Description

b)(6)
COMPASS5 M A Automated Calling Process
COMPASS5M A User Request Screen
COMPASS5 M I Activity Detail Screen
COMPASS5 M A,C,D I, Public Service Loan Forgiveness
COMPASS5M C, I Borrower Demographics
Work Queues/ Action Request Codes (ARCs)
Name Code Description

b)(6)
LTR-BRWNME DISCREP Borrower Name Discrepancy Letter
PSLFIDR REVIEW PSLF IDR Review
PUB SRV NON PRFTREV Public Service Non-Profit Review
PSLFREVIEWECF Review ECFfor PSLF
LTR-PSLFMANUAL DNL Sending Specialized PSLFEmployer Denial Letter
Scripts
Name Administrator Description

OF INFORMATION ACT
Not Applicable
PageCenter Reports
Pageset Name Description
Not Applicable
SAS Jobs
Name Description
Not Applicable
Other
Name Description
(b)(6)
Employer Outbound Call Tracking
spreadsheet
I RS EO Select Check htt(J:LLwww.irs.gov LatJtJLtJu b-7 BL
IRS SOI Tax Stats - Exempt Organizations htt[Js:LLwww.irs.govLCharities-&-Non-ProfitsLExem[Jt-

Business Master File (BMF) Organizations-Business-Master-File-Extract-EO-BMF
b)(6)
Processing Comment Document
~
PSLFLetter QA
~
PSLFLetter QA\Correction Required Folder

~
PSLFLetter QA \Corrected Folder
htt(J :LLwww.usa.gov LAgen cies. shtm I

USA.gov - Agencies
htttJ:LLwww.bia.govLWhoWeAreLB1AL01SL
USA.gov-Tribal Governments
Tri ba IGovern me ntSe rvicesLT ri ba IDi recto ryLi nd ex. htm

OF INFORMATION ACT
Appendix A - Frequently Asked Questions
Ql: The borrower provides a middle initial on the ECFform. Per review of NS~e middle initial is
not listed and does not show in history. Should the middle initial be added tLJ
Al: If the middle initial is not listed or found in history on NSLDS,it should not be added to
~
Q2: The borrower does not provide a middle initial on the ECFform. Per review of NSLDS,a middle
initial is listed. Should the middle initial be added to~?
A2: Yes, the middle initial should be added tJbJ(Bl [
Q3: The borrower's employment time period is prior to the start of the Public Service Loan
Forgiveness Program. How should the employment dates be entered into~
A3: If the borrower's employment time period is prior to October 1, 2007, the begin and end
dates should be switched when entered into ITL2U. This will cause the ECFto be denied for
invalid dates.
Example: The borrower's employment begin date is 4/14/2005 and the end date of
employment is 10/25/2006. Since both the employment begin and end dates are prior to
October 1, 2007, the date 10/25/2006 should be entered in the employment begin date field
and 4/14/2005 should be entered into the employment end date on ITL2U. Entering the
employment begin and end dates backwards will cause the system to deny the ECFfor invalid
employment dates.
Note: Backwards dates will not appear in the denial letter that goes to the borrower, because the
processor will bypass the system letter and send the manual letter.
Q4: The complete name of the employer will not fit in the Employer Name field on ITL2U.
A4: Abbreviate the em~r's name if the complete name of the organization will not fit in
the Employer Field on~. Notate the complete name of the organization on the comment
screen of~

OF INFORMATION ACT
Appendix B - Loan Abbreviations
Loan Types FFELP Direct

Subsidized Stafford STFFRD DLSTFD
Unsubsidized Stafford UNSTFD DLUNST
SDCL - Subsidized Stafford N/A DLSCST
SDCL - Unsubsidized Stafford N/A DLSCUN
TEACH - Unsubsidized N/A TEACH
Consolidation CNSLDN DLCNSL

Subsidized Consolidation SUBCNS DLSCNS
Unsubsidized Consolidation UNCNS DLUCNS
SDCL - Consolidation N/A DLSCCN
SDCL - Subsidized Consolidation N/A DLSCSC
SDCL - Unsubsidized Consolidation N/A DLSCUC
Parent PLUS PLUS DLPLUS

Graduate/ Student PLUS PLUSGB DLPLGB
SDCL- Parent PLUS N/A DLSCPL
SDCL- Graduate/ Student PLUS N/A DLSCPG
Federal Insured Student Loan FISL N/A

SDCL - Federal Insured Student Loan N/A DLSCST
Supplemental Loan for Students SLS N/A
SDCL - Federal Supplemental Loan for
Students N/A DLSCST
Guaranteed Student Loans GSL N/A
SDCL- Guaranteed Student Loans N/A DLSCST
Appendix C - Digital Signatures

It is important to note that ONLY the following types of signatures are acceptable for processing:
o Original wet signatures,
o Digital facsimile signature (or a digitally drawn signature) which is a signature that looks wet
even if it was digitally applied. This includes DocuSign where a borrower/employer would draw
their signature on an electronic pad such as a credit card or touch-enabled device.
o Copied and/or fax print of wet signatures,

OF INFORMATION ACT
o Embedded signatures from the Department of Education's (the Department)

www.studentloans.gov website, and
o Embedded signatures that were completed through a process in compliance with our E-Sign
procedures
We CANNOT accept the following signatures for processing:

o Signatures that appear to be in font
o Signatures that indicate that they were 'Digitally Signed'.
When you come across an application where it is difficult to tell if the signature is acceptable, please
forward an email request to the FLSPSLFSupervisor Review in box. Provide a brief explanation, a
screen shot of the signature, the SSN and the Document Control Number (DCN) of the image.
Examples of Acceptable versus Not Acceptable Digital Signatures:

Not Acceptable:
JohvvSwu;th,
John Smith
Acceptable:
Tol'llllltR...
I I , ( •-' ••
I
I
This signature has the "DocuSigned by'' logo and is considered acceptable.
Resources/Authority
§685.219

OF INFORMATION ACT
Send all Change Request Forms to POCChangeReguest@ed.gov

Administrative Information
Service Area Validation for Submission Completed: D Defer: D ID:
Requester: Date
Cynthia Battle Submitted: 09/30/11
Title of change
request: PSLF - Single Servicer Anticipated Implementation Date: 01/15/2012
FSA Service/System/Area Impacted

[,'I ACES Nelnet Platform [,'I NSLDS □ EAi
[,'I Not-for-Profits (NFPs) □ FPDM □ PEPS/I PM
[,'I Title IV Servicers (TIVAS) □ CPS □ FMS
□ TPD
□ Participation Management □ Security Architecture
□ DMCS/DMCS2
□ eCampus-Based
ED Express
□ AIM
SAIG
□ DLCS
□ □
□ COD
□ IFAP [8J Other_ FSAIC
Details
Description of Change Requested:
The College Cost Reduction and Access Act (CCRAA) of 2007 created a new loan forgiveness program for Direct Loan
borrowers who make 120 payments. These payments must be made after October 1, 2007 and the borrower must be
employed in certain public service jobs, as defined in the regulations, during the time the payments are made and at the
time forgiveness is requested and granted. Once the Department determines whether all of the requirements for eligibility
have been fulfilled, the balance of principal and interest due on the borrower's eligible Direct Loans shall be forgiven.
For the purpose of this change control, the numbering sequences are as follows:
100 - Federal Loan Servicers requirements

200 - PSLF Single Servicer requirements
300 - NSLDS requirements
Req # Requirement Validation Artifact

100.00 The federal loan servicers shall provide the Employment Certification Commitment
package (to be provided by FSA), which includes the Dear Borrower statement
Letter, Instructions for Completing the Employment Certification, and the
Employment Certification for Public Service Loan Forgiveness, to the
borrower, at the borrower's request. See Appendix A- Draft PSLF
Employment Certification package.
100.01 The Public Service Loan Forgiveness Program Employment Certification Procedure
package and other information (e.g., PSLF Fact Sheet) shall be provided on
borrower request.
100.02 The provision of the Public Service Loan Forgiveness Program Employment Screen shots of
Certification package and information shall be recorded in the account.
borrower's/recipient's correspondence and account history records.
101.00 The federal loan servicers shall transfer all requested federally held loans TBD
(including PSLF-eligible Direct Loans and PUT loans) and
account/servicing history files for PSLFon-track borrowers, to the PSLF
servicer upon request, according to existing transfer protocol.
Revised: 9/21/2011
200.00 The PSLFservicer shall provide the Employment Certification package {to Commitment
be provided by FSA), which includes the Dear Borrower Letter, statement
Instructions for Completing the Employment Certification, and the
Employment Certification for Public Service Loan Forgiveness, to the
Employment Certification package.
200.01 The Public Service Loan Forgiveness Program Employment Certification Procedure
package and other information (e.g., PSLFFact Sheet) shall be provided on
borrower request.
200.02 The provision of the Public Service Loan Forgiveness Program Employment Screen shots of
Certification package and information shall be recorded in the account.
borrower's/recipient's correspondence and account history records.
201.00 The PSLFservicer shall collect the Employment Certification form, Procedure for
conduct an initial review, and retain the ECFfor the borrower. completing initial
review.
201.01 The initial review shall check that the borrower provided all required Procedure for
information on the submitted form. If the form is determined to be collecting missing
information and
incomplete, the PSLFservicer shall communicate with the borrower and sample notification.
collect the missing information.
201.02 Retention of the original form requires maintaining an imaged copy of the Procedure.
original on the PSLFservicer's system until the Department grants
forgiveness for the borrower.
202.00 The PSLFservicer shall determine whether an employer is a qualifying Commitment

public service organization, based on the submitted Employment statement.
Certification form.
202.01 The PSLFservicer shall follow procedures for validating qualifying public Provide procedure.
service, according to a validation process approved by FSA, which will
Also provide
includes looking up employers in searchable databases, based on the type examples of test
of public service organization. See Appendix B-(Draft) Instructions for borrowers for whom
Validating a Qualifying Public Service Organization the PSLF servicer
completed validation
of ECFs.
202.02 The PSLFservicer shall escalate to FSAcases for which a public service Procedure.
organization cannot be determined to be qualifying or non-qualifying,
based on the provided validation process.
202.03 The PSLFservicer shall determine whether the borrower has met the full- Procedure.
time requirement, as provided in the regulations, while employed by the
qualifying public service organization, based on the hours indicated on one
or more certifications.
202.04 The PSLFservicer shall have the ability to override judgment of public Procedure.
service employers, per FSAauthorization and on an exception basis, to
make them qualifying or not qualifying employers for the Public Service
Loan Forgiveness Program. The PSLFservicer shall note the FSA-
Revised: 9/21/2011
authorized condition on the borrower account.
203.00 The PSLFservicer shall request the transfer of all federally-held loans TBD
(including PSLF-eligible Direct Loans and PUT loans) and
account/servicing history files from the borrower's original servicer(s),
once a valid ECFis processed (see Requirement 202).
Validation Artifact (added 12/29/11)
1.Provide procedure for transfers, including supplemental payment

history data template.
2. Also provide examples oftest borrowers with valid ECF1 s with the
following conditions:
a. Eligible loans for transfer
b. Ineligible loans for transfer based on following scenarios:
i. Highly delinquent status
ii. Bankruptcy
iii. Pending consolidation (Provide procedure)
3. Borrower communication related to transfer eligibility may be
included here or as part of validation artifact for requirement
206.01
204.00 The PSLFservicer shall determine if PSLFqualifying payments were made Procedure for
on eligible loans, and track the number of PSLFqualifying payments determining PSLF
made after the loans are transferred from the original servicer.
Screen shot of test
borrower with
qualifying payment
tracking record,
post-transfer to
PSLF servicer.
204.01
All Direct Loan Program loan types shall be included in the payment
tracking for the Public Service Loan Forgiveness Program.
204.02
The PSLFservicer shall consider payments made after October 1, 2007
while the borrower is on the following eligible repayment plans, for
tracking purpose for the Public Service Loan Forgiveness Program:
L The Income-Based Repayment (IBR) plan;
ii. The Income Contingent Repayment (ICR) plan;
iii. The Standard Repayment plan based on a 10-year repayment term

(note that payments made on the Standard Repayment Plan for
Direct Consolidation Loans only count as qualifying payments for
PSLFif the term does not exceed 10 years); and
iv. Any repayment plan other than IBR and ICRwhere the monthly
installment is equal to or greater than the Standard Repayment
Revised: 9/21/2011
plan based on a 10-year repayment term.
204.03
Borrowers must make 120 separate on-time qualifying payments after
October 1, 2007 to be eligible for the Public Service Loan Forgiveness
Program.
i. All 120 payments must be made after October 1, 2007 to be

eligible for the Public Service Loan Forgiveness Program.
ii. For the Public Service Loan Forgiveness Program, payments shall
be considered on-time when they are received no later than 15
days after the scheduled payment date.
iii. For the Public Service Loan Forgiveness Program, a qualifying

payment must satisfy the full current payment due amount for
that month.
iv. Borrower prepayments (payment amounts equal to or more than

one full monthly payment amount) shall only count as one on-time
payment when tracking for qualifying payments for the Public
Service Loan Forgiveness Program.
204.04 Screen shot of test

Payments made while the borrower is in an in-school, in-grace, deferment, borrowers showing
qualifying payment
forbearance or a suspended activity status shall not be included as
not applied due to
qualifying payments for the Public Service Loan Forgiveness Program. non-repayment
status.
Payments made on a loan while it is in a default status shall not be borrowers showing
qualifying payment
included as qualifying payments for the Public Service Loan Forgiveness
not applied due to
Program. This includes payments made as part of a rehabilitation default status.
agreement on a defaulted loan.
i. For purposes of determining qualifying payments for the Public

Service Loan Forgiveness Program, default status means greater
than 270 days delinquent.
204.06 Procedure for

A lump sum payment made by AmeriCorps volunteers using all or part of a applying the
AmeriCorps/Peace
Segal Education Award or Peace Corps volunteers using all or part of a
Corps exception for
Peace Corps transition payment shall be considered to have made up to lump sum payments
twelve qualifying payments per borrower, as allowed in the regulations. to be considered
qualifying for PSLF.
The PSLFservicer shall track a borrower's expected eligibility date for the borrower with
expected eligibility
Public Service Loan Forgiveness Program.
date adjustments
due to non-
i. The expected eligibility date shall adjust due to periods of non- qualifying payments.
repayment (including periods of in-school, in-grace, deferment,
forbearance, and suspense status) and non-qualifying payment
Revised: 9/21/2011
(including delinquency and payments made that are less than the
current full scheduled payment amount).
204.08
The PSLFservicer shall have the ability to override payments, per FSA Procedure.
authorization and on an exception basis, to make them qualifying or not
qualifying payments for the Public Service Loan Forgiveness Program. The
PSLFservicer shall note the FSA-authorized condition on the borrower
account.
205.00 The PSLFservicer shall match qualifying payments that were made Commitment
during the periods indicated on the Employment Certifications. statement.
205.01 The PSLFservicer shall determine if the qualifying payments were made Provide procedure
while in qualifying employment. for matching
qualifying payments
with qualifying
i. Count each month from the Start Date to End Date (Section 3 Item
employment.
2a of ECF),for which a qualifying payment was made. For the first
month, the actual payment date must be on or after the Start Also provide
Date. For the last month, the actual payment date must be before examples of test
borrowers for which
the End Date last month of each Employment Certification. For
qualifying payments
Part-time employees, these conditions apply to each employer. and employment
have been matched.
ii. For partial payments made, the actual payment date is the date on
which the total of partial payments equals to or is greater than the
full scheduled payment due amount for that month.
iii. The scheduled payment date will determine the calendar month
for which the qualifying payment is counted.
Example: Scheduled payment date is July 1 but actual payment

date is June 29. Assuming the borrower does not have previous
delinquencies, the qualifying payment applies to July.
205.02 The PSLFservicer shall use data contained in the borrower account and Provide procedure.
servicing history files to determine whether qualifying payments were
made while the borrower's loans were with the original servicer, for the
period of qualifying employment.
205.03 A monthly qualifying payment or calendar month of qualifying

employment can only be matched and counted once towards the 120
months required to apply for PSLF.
Example: Borrower submits ECFfrom Employer X for dates

January-December 2012. The following year the certification from
Employer X includes dates January 2012-December 2013. Since 12
months were already matched with qualifying payments for 2012,
the new certification would only match the 12 months for 2013.
205.04 The same period of service may not be used to qualify for PSLFand
Teacher Loan Forgiveness, Service in Areas of National Need, and the Civil
Legal Attorney Assistance and Student Loan Repayment Programs.
Revised: 9/21/2011
206.00 The PSLFservicer shall include PSLFin existing procedures for Commitment
communicating with borrowers throughout the form collection and Statement.
review process when applying for a non-discretionary benefit, in
compliance with existing Departmental guidelines (see CR #1258-
Compliance with Higgins Decision). FSA will provide additional guidance
on language specific to the PSLFProgram, as necessary.
206.01 The PSLFservicer shall maintain records of all communications with Electronic catalog of
borrowers throughout the form collection and validation process. FSAwill forms, letters, and
correspondences
provide additional guidance on language specific to the PSLFProgram, as the PSLF servicer
necessary. uses to
communicate with
the borrower
Separate written communications should be provided to borrowers: regarding qualifying
payments, qualifying
employment, and
i. Confirming that the Certification form was received, PSLF eligibility
status/tracking.
ii. Informing borrowers of the process of validating qualifying
employment, including the roles and responsibilities of all entities
involved in the process,
iii. Describing the actions the borrower may take if any required
information is missing or if the employment cannot be
determined to be qualifying, or to dispute a determination, and
iv. The outcome of the initial review.
206.02 Upon concluding the initial review of the Employment Certification form, See 206.01.
the PSLFservicer shall notify the borrower in writing or electronically of
the number of qualifying payments made while employed in qualifying
public service, based on the dates indicated on the current and previously
submitted certifications, and the remaining number required towards
becoming eligible for PSLF.(Note that a borrower must apply for PSLF
using an application form that shall be provided by the Department, and
that a borrower is also required to be employed in qualifying public service
when applying for and receiving forgiveness).
i. The PSLFservicer shall include in the notification a statement

which reminds the borrower that to receive any forgiveness
under the PSLFProgram most of the loan payments must be
made under IBR or ICRto have any remaining loan balance after
120 payments have been made.
207.00 The PSLFservicer shall track the number of matched months to Commitment
determine when a borrower has reached 120 and is eligible to apply for statement.
PSLF.
207.01 Screen shot.

The PSLFservicer shall display a borrower's PSLFtracking data at the loan
Revised: 9/21/2011
level on the borrower view.
208.00 The PSLFservicer shall replace the data elements contained in the Screen shot of
existing PSLFReport requirements with new data elements as instructed, sample report.
and provide the Report to FSA on the requested schedule. See Appendix
C- Sample PSLFReport
209.00 The PSLFservicer shall report tracking information (matched months) to 1STwith NSLDS
NSLDS on a new record type per instructions published in the Data (appropriate
interface
Provider Instructions, as required for performing GE calculation.
documentation)
300.00 The NSLDSshall create a solution to collect, store and display a Procedure.
borrower's PSLFtracking summary on the Student Access Web site.
300.01 The NSLDScontractor shall deliver the DPI change pages within 3 weeks of
the award date.
300.02 NSLDSshall collect and store borrower PSLFtracking information (matched

month data) at the loan-level.
300.03 NSLDSshall display PSLFtracking data received from the PSLFservicer on Screen shot of test
the NSLDSFAPWeb site at the loan-level and borrower-level. borrower.
300.04
NSLDSshall make PSLFtracking data reportable and updatable via Online
Loan Update for the PSLFservicer only.

NSLDSshall create a solution to display PSLFtracking data received from borrower.
the PSLFservicer on the NSLDSStudent Access Web site at the loan-level
and the borrower-level.
300.06 Package of forms

NSLDSshall make the Employment Certification package available for and a statement of
download on the Student Access Web site. See Appendix A- Draft PSLF how a borrower may
obtain the forms
Employment Certification package. from the servicer.
300.07
NSLDSshall create a solution to allow borrowers to download the
Employment Certification package, with the option of pre-populating
borrower and PSLFservicer information on the Employment Certification
form, from the Student Access Web site.
300.08 Screen shot.

NSLDSshall link between the PSLFservicer and the NSLDSStudent Access
Web site to create a seamless browsing experience for the borrower.
300.09 Screen shot.

NSLDSshall update the NSLDSExit Counseling Web pages to include PSLF
information, a link to the NSLDStracking page, and a link to the PSLF
servicer.
Revised: 9/21/2011
300.10 Commitment
The Federal Student Aid Information Center shall continue with existing statement.
support functionality by counseling borrowers on how to access the
borrower view on NSLDS,including the new PSLFtracking summary page,
using a borrower pin. For any specific inquiries regarding a borrower's
tracking status, a borrower shall be referred to the PSLFservicer.
Reason for Change:
The purpose of this change request is to implement a PSLFservicer to enable borrowers to track qualifying
payments and employment, using the Employment Certification form, while in the process of qualifying for PSLF.
Any borrower who is declared on-track for PSLFwill be transferred to the PSLFservicer, who will process all forms
and handle all communications regarding PSLF,as well as perform all non-PSLF related servicing functions on a
borrower portfolio, as required of all federal loan servicers. PSLFsummary tracking information will be reported by
the PSLFservicer to NSLDSfor purposes of data collection relating to implementation of forthcoming gainful
employment regulations.
•This requires the PSLFservicer to be able to:

• Collect, review and retain the submitted employment certifications;
• Receive all eligible loans and provide comprehensive servicing of all federally held loans to borrowers who
may or may not ultimately be eligible for forgiveness based on public service.
• Determine that the borrower has made qualifying payments while employed in qualifying public service;
• Track PSLFeligibility status for the on-track borrower; and
• Report tracking information to NSLDS.
Additional Information (ALL OPERATIONAL IMPACTS MUST BE ASSESSED):
Key Terms:
• "Qualifying payments" refer to those payments that meet all criteria specified in Requirement
#7, independent of the borrower's employment status.
• "Matched months" refer to those months for which qualifying employment has been validated
and matched with months of qualifying payment. These months are eligible to count towards
the 120 required to apply for PSLF.
• "Valid Employment Certification form (ECF)" is a complete, signed and dated form, which is
certified by an authorized official from a validated qualifying public service organization.
PSLFSingle Servicer Process Design:

• A borrower is declared "on-track" for PSLFby submitting a valid Employment Certification form
(ECF).Once an ECFis validated, the PSLFservicer will request (pull) the borrower's loans from
the original servicer(s), where they will remain until the outstanding balance of the loan(s) are
discharged, paid in full, or defaulted on.
• The PSLFservicer would handle the tracking of qualifying payments, collection and review of all
ECFsand related communications, matching of qualifying payments with periods of qualifying
Revised: 9/21/2011
public service employment, and processing of forgiveness when the borrower is eligible and
applies for this benefit.
• For a borrower submitting an ECFto the PSLFservicer for the first time, if the form is
determined to be incomplete or does not support PSLFqualifying employment, the PSLF
servicer would communicate with the borrower but would not pull the loans from the existing
servicer until the borrower submits a valid ECF.
• All qualifying payments made prior to transfer to the PSLFservicer must be looked up using the
borrower history and servicing records, in order to match with periods of employment.
1ST Anticipation:
Validation (Requirement ID/Criteria):
See table.
Does this change require a new network connection (Secure File Transfer Protocol is mandatory for all
new connections)?
Revised: 9/21/2011
APPENDIX A
PSLF Employment Certification Package [DRAFT)
Page 11 of27
Public Service Loan Forgiveness Program
Dear Borrower.
Thank you for your interest in the Public Service Loan Forgiveness (PSLF) Program for William D. Ford Federal Direct Loan Program
(Direct Loan) borrowers. Enclosed you will find the Employment Certification for Public Service Loan Forgiveness (Employment
Cert1f1cationform) and the accompanying Instructions 1or Completing the Employment Certif1cat1onform.
The purpose of the PSLF Program is to encourage individuals to enter and continue in full-time public service employment by forgiving
the remaining balance of their Direct Loans alter they have made 120 qualiiying monthly payments on those loans while employed in
public service. This letter explains the eligibility requirements of the PSLF Program, how you can verify that your employer qualifies as
a public service organization, how to track your qualifying PSLF payments, and the process for applying for forgiveness of your Direct
Loan(s) alter you have met the elIgibilIty requirements.
Checklist of Eligibility Requirements for Public Service Loan Forgiveness

The following checklist will help you determine if you may be eligible for PSLF. You are eligible for PSLF if:
□ You are not in default on the loan(s) for which you are requesting forgiveness.
□ You have made 120 separate, qualifying monthly payments* after October 1, 2007 on the Direct Loan(s) for which you are
requesting forgiveness under one or more of the following repayment plans:
o The Income-Based Repayment (IBR) Plan;
o The Income Contingent Repayment (ICR) Plan;
o The 10-Year Standard Repayment Plan" (Standard Repayment Plan with a maximum 10-year repayment period):
oc
o Any other Direct Loan repayment plan. in which your monthly payments equal or exceed the monthly payment
amount that would be required under the 10-Year Standard Repayment Plan.
NOTE:These 120 payments do not need to be consecutive.
□ You made each of the 120 monthly payments on time (no later than 15 days of the scheduled due date) and for at least the full
scheduled installment amount.
□ You were employed full-time by a public service organization(s) or serving in a full-time AmeriCorps or Peace Corps position
at the time you made each of the required 120 qualifying monthly payments. Please see Section 5 of the Employment
Certification form for the definitions of '·full-time" and "public service organization:·
□ You are employed full-time by a public service organization(s) or serving in a full-time AmeriCorps or Peace Corps position at
the time you apply for loan forgiveness and at the time 1orgIveness is granted.
• If you were an AmeriCorps or Peace Corps volunteer, you may receive credit for making up to 12 qualifying payments if you
make a lump sum payment using all or part of a Segal Education Award or a Peace Corps transition payment. See Section 4 of the
enclosed PSLF Employment Certification Form for details.
"IMPORTANT: The Standard Repayment Plan for Direct Consolidation Loans entered on or after July 1 2006 have varying
repayment terms based on the loan amount. For purposes of qualifying for PSLF, monthly payments you make under the
Standard Repayment Plan on a Direct Consolidation Loan are only qualifying payments if made under the 10-year repayment term.
You must verify all of your qualifying public service employment using the Employment Certification form(s). which you may submit
while working towards fulfilling the eligibility requirements for PSLF. Once you have fulfilled all eligibility requirements, you may apply
1or forgiveness by submitting a Public Service Loan Forgiveness ApplIcatIon. More iniormatIon on these 1orms Is below.
Employment Certification for Public Service Loan Forgiveness

To qualify for PSLF, you are required to submit verification of your qualifying public service employment using the Employment
Certification forms. Read the accompanying Instructions for Completing the Employment Certification form, which includes instructions
1or you and your employer.
You will need to submit completed Employment Certification form(s) to document that you were employed full-time by a public service
organizatIon(s) when you made each of the 120 qualIfyIng monthly payments. An authorized official of each public service organization
that you worked for while making the required payments must complete, sign and date your Employment Certification form(s).
11you intend to apply 1or PSLF, we suggest that you collect employment certIfIcation(s) from your qualifying employer(s) while you are
making the required 120 qualifying monthly payments on your loans. You may submit the Employment Certification form(s) annually,
whenever you change employers, or when you apply for PSLF after you have met the eligibility requirements for loan forgiveness.
If you choose to submit Employment Certification form(s) before completing the 120 payments and applying for PSLF, you must send
them to your Direct Loan servicer, who manages the repayment of your Direct Loan(s) on behalf of the U.S. Department of Education
(the Department). The Department will conduct an InitIal review to check the Employment Cert1f1cationform(s) are complete, your
employer qualifies as a public service organization. and the loan payments you made during the period covered by the Employment
Certification forms are qualifying payments.
Benefits of submitting the Employment Certification form(s) before you apply for PSLF:
• The Department will retain the original certification(s) for you until you apply for PSLF.
• The Department will acknowledge receipt of your Employment Certification form, ensure the form was 1illed out completely, and
determine whether your certifying employer is a qualifying public service organization.
Page 12 of 27
• The Department will match your qualifying loan payments to the months you were employed by a qualifying public service
organization, based on the dates provided on your Employment Certification form. You will be notified in writing of the number
of qualifying payments you have made and the remaining number of qualifying payments you must make before you are eligible
to apply for PSLF.
• When you send in your application for loan forgiveness, you do not have to re-submit Employment Certification forms for
periods of employment that have already been validated by the Department.
• Collecting and submitting the Employment Certification form(s) while you are making the required 120 qualifying monthly
payments will help you keep track of when you will be eligible to apply for PSLF.
Note the following:

• If the Department determines that the form(s} you submitted is incomplete, that your employer does not qualify as a public
service organization, or that your loan payments made during the period covered by the Employment Certification(s) are not
qualifying payments, the Department will notify you in writing, along with the reason(s} for the determination(s} and the steps
you must take to complete or correct the previously submitted form(s).
• If you submit the Employment Certification form before you are eligible for PSLF, the Department will use it to validate that your
employer is a qualifying public service organization, as defined in the regulations. However, the Department cannot determine
if you are eligible for loan forgiveness until you have submitted a Public Service Loan Forgiveness Application to your Direct
Loan servicer.
• You may qualify for forgiveness of the remaining balance of your Direct Loan(s) only after you have made all 120 qualifying
monthly payments while provIdIng qualifying public service, as described above. You do not receive partial iorgIveness based
on making a lesser number of qualifying monthly payments.
• To qualify for loan forgiveness you must be working for a qualifying public service organization at the time you apply ior loan
forgiveness and at the time forgiveness is granted by the Department.
• You should keep copies of any Employment Certification form(s) you submit to your Direct Loan servicer ior your records.
Public Service Loan Forgiveness Application

Only qualifying payments made after October 1, 2017, while employed in public service, may be counted toward the required 120
monthly payments. You may only submit the Public Service Loan Forgiveness ApplIcatIon after you have made all 120 qualifying
payments and met all of the other eligibility requirements, as described above. Therefore, the earliest date that any borrower will be
eligible to apply for and receive loan forgiveness is October 2017. The Public Service Loan Forgiveness Application will be available to
the public beiore October 2017.
After you submit the Public Service Loan Forgiveness Application, the Department will review your Application and any Employment
Cert1f1cationsnot previously validated by the Department, and determine ii you have fuliilled all of the requirements to be elIgIble for
PSLF.
Supporting Documentation of Employment

11is very important that you keep records of your qualifying public service employment-including W-2 forms, pay stubs, and any other
documents demonstrating your qualiiyIng employment-in addition to copies oi any completed Employment Cert1f1cat1oniorms you
submitted to the Department to review. In some cases. the Department may require you to provide additional supporting documentation
of your qualiiying employment.
If you are unable to obtain an authorized official's signature on the form because you were employed at a public service organization
that no longer exists, complete Section 3 of the Employment Certification form according to the guidance under Instructions for
Borrowers when there is No Authorized Official. When requested, you must be able to provide the Department with suiiicIent evidence
that supports your qualifying employment and the status of your qualifying public service organization at the time of your employment.
Please do not submit any documentation other than completed Employment Certification forms unless requested to do so by the
Department. If you fail to provide the Department with additional evidence of your qualiiying public service employment upon request,
the Department will be unable to complete its review and your employment indicated on the form cannot be deemed qualifying.
Time Required tor Review of Employment Certification Forms
Generally, it will take 30-60 days for the Department to complete its review of any Employment Certification forms you submit and to
determine whether your employer is an eligible public service organization. Processing may take longer if your Employment
Cert1f1cationforms are incomplete or ii you or your employer does not reply promptly to requests ior more information.
Additional Information and Assistance

For addItIonal information on the Public Service Loan Forgiveness Program, including a Fact Sheet and O&As see the U.S
Department of Education's Public Service Loan Forgiveness Web site or contact your Direct Loan servicer.
Page13of27
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Instructions for Completing Employment Certification for BOX]
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Public Service Loan Forgiveness (PSLF}
William D. Ford Federal Direct Loan Program
Before You Be m Item 3: Enter your permanent address (number. street, apartment
Carefully read the enclosed Dear Borrower Letter for information about the number, or rural route number and box number, then city. state . .:Ip
el1gib1l1tyrequirements of the Public Service Loan Forgiveness (PSLF) code). If your mailing address ,s a post office box or general delivery, you
Program. the means by which you may track your qualifying public service must 11stboth your permanent address and mailing address.
employment, and the process for applying for loan forgiveness. Item 4: Enter the area code and telephone numbers for your home
telephone and any other telephone at which you can easily be reached.
(Do not 11styour work telephone number here.) If you do not have a
Instructions for the Borrower: telephone, enter N/A
Use as many Employment Certification forms (pages 1-2 only) as needed to
Item 5 (optional): Enter your preferred e-mail address for receIvIng
certify your full-time public service employment while making the required
commun,cat,ons. If you provide ,1. we may use your e-ma,I address to
120 separate. qualifying monthly payments. These 120 qualifying payments
communicate with you.
do not have to be consecutive For periods in which you are/were
concurrently working part-time with more than one public service
employer and the total average hours you worked per week meets the SECTION 2: BORROWER'S CERTIFICATION REQUESTS,
definition of full-time employment, submit an Employment Certification AUTHORIZATIONS, AND UNDERSTANDINGS
lorm (pages 1-2) for each employer.
Carefully read the requests. authorizations. and understandings in this
You must obtain an authorized official's certification on the Employment section and sign and date the form. Before signing, carefully review the
Cert,ficat,on form. which you may submit to your Direct Loan servicer. The entire PSLF employment cert,r,cation package, including the Employment
U.S. Department of Education contracts w,th serv,cers lo answer questions Certification form. these Instructions and lhe Dear Borrower Letter.
about and manage the repayment on Direct Loans. Submission of
Employment Certification forms before you are eligible to apply for
SECTION 3: CERTIFICATION OF EMPLOYMENT
PSLF is optional but we encourage you to submit certifications
annually or whenever you leave a qualifying position. Validating your Enter your name and nine-digit Social Security Number at the top of page 2.
employment while you are still employed at a qualifying public serv,ce 11not preprinted.
organization or soon thereafter 1s advisable in case your organization closes An authorized official from the public service organization at which you
or Is otherwise unable to provide a certlf1cat1onwhen you apply for PSLF. If are/were employed must complete Section 3. If any requested 1nformat1on
you choose not to submit Employment Cert,ficat,on forms while making the ,s incomplete or m,ss,ng, the Department cannot validate the cert,r,cat,on
required 120 qualifying monthly payments. you will have to submit them
when you apply for PSLF. Instructions for the Authorized Official (see Section 5 of the Employmenr
Cemticatton form for defmit,on of Authorized Offic1a/):
If the Department receives an Employment Certification form from you
before you are eligible to apply for forgiveness, the Department will retain Item 1: Provide the requested information about the public service
the form(s) you submit until you submit the PSLF application. The organization at which the borrower is/was employed. including the
Department will conduct an initial rev,ew lo check that lhe Employment organization's name, permanent address, and federally assigned Employer
Cert,ficat,on form(s) are complete. that your employer qualifies as a public ldentif,cat,on Number (EIN). which will be used to verify inrormat,on about
service organization. and that the loan payments you made during the your organization.
period covered by the Employment Cert1l1cationform(s) are qualifying Item 2a: Provide the borrower's starting and ending dates of employment. If
payments. lhe borrower is still employed w,th your organization at the lime the
If you submit the Employment Certification form(s) to the Department before cert1f1cat1001s completed, put today's date as the ending date.
you submit the application for PSLF you must still submit an Employment
Item 2b: Check the box that describes the borrower"s employment status
Cert1ficat1onform for the public service organization that employs you at the
Full-time employment must be ,n accordance with the def1n1t1on,n Section 5
t,me you apply ror and are granted loan forgiveness
or the Employment Cert1f1cat1onform. Provide the average number or hours
INSTRUCTIONS FOR COMPLETING AND SUBMITTING THE per week the borrower is/was employed. either full-t,me or part-t,me, at your
EMPLOYMENT CERTIFICATION FOR PUBLIC SERVICE LOAN public service organization.
FORGIVENESS Item 3: Check the box next to the category which best describes your public
service organization. If your organization is a private organization that
Type or print using blue or black ink. provides public serv,ce(s)-category (c) only-check the box(es) that
Show dates as mm-dd-yyyy (for example, show "January 15, 2010"' as describes the type(s) of public serv,ce(s) ,t provides A private organization
"01-15-201 O"). does not qualify as a public serv,ce organization if il does nol provide one of
the listed public services. or if it is a business organized for profit. a labor
If any ,nformat,on is crossed out or altered ,n Sections 1 or 2. you must
union. a partisan political organization. or an organ1zatmn engaged in
initial bes,de the change; any changes in Secl,on 3 must be initialed by
rel1g1ousactivities, unless the qualifying act1v1tiesare unrelated to religious
your employer. If the alteration is not initialed. the Department may return
InstructIon, worship services, or any form of proselyt1z1ng
this form to you.
Certification: Carefully read the cert,ficat,on statement. Print your full name
Keep a copy of each completed Employment Cert1ficat1onform for your
and official title in lhe spaces provided and provide a telephone number
records.
where you can be reached if additional information or documentation 1s
Mail the original completed Employment Cert1f1cationform (pages 1-2 needed. Sign and date In the spaces provided. Show dates as mm-dd-
only) to your Direct Loan servicer YYYY-
You should also retain copies of additional documents that confirm Return the completed Employment Cert1f1cat1onform to the borrower.
your qualifying employment with the public service organization(s), but do
not submit these supporting documents to the Department unless the
Department requests them. Such documents may include: Instructions for the Borrower when there is no Authorized Official: If
the organization has closed or you are otherwise unable to obta,n
W-2 forms cerl,fical,on from an authorized official. check lhe box under th,s heading.
Pay stubs and complete Sectmns 1.2. and 3. You will be required to provide to the
Any other documentation related to your qualifying employment or Department add1t1onaldocumentation with sufficient evidence to validate
your employer(s) that you believe would establish eligibility as a public your qual,ry,ng employment
service organization(s).
SECTION 1: BORROWER IDENTIFICATION IMntMffi

Provide the requested inrormat,on about yourself, If not preprinted: For help completing this form. call your Direct Loan servicer. If your
serv,cer's contact information ,s not preprinted in Section 6 on the
Item 1: Enter your n,ne-dig,t Social Security Number Employment Certification form, you can look th,s up on the National Student
Item 2a: Enter your last name, then your first name and middle ,n,tial. Loan Data System (NSLDS) at http://www.nslds.ed.gov/. Additional
1nformat1oncan be found on the Public Service Loan Forgiveness Web
Item 2b: Enter any other name. such as a former or maiden name. under fl..'!9..§., including a Fact Sheet and Q&As.
which you applied for and were granted Direct Loan(s)
Page 14 of 27
*•• DEPARTMENT USE ONLY••• 0MB No. 1845-xxxx
ORIGINAL RECEIPT DATE Form Approved
E,p Date x,I,x;xxx,
Error!
Objects Employment Certification for Public Service Loan Forgiveness (PSLF)
cannot be William D. Ford Federal Direct Loan Program
created WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on any accompanying documents is
from editing subject to penalties that may include fines. imprisonment, or both, under the U.S. Criminal Code and 20 U.S.C. 1097.
field codes.
INSTRUCTIONS FOR COMPLETING AND SUBMITTING THIS EMPLOYMENT CERTIFICATION
Read the accompanying instructions for completing this Employment Certification for Public Service Loan Forgiveness. Type or print using
blue or black ink. You must sign and date this form in Section 2 and an authorized official from the public service organization which
employs/employed you must completely fill out, sign, and date Section 3. If any information is crossed out or altered in Sections 1 or 2. you
must initial beside the chanoe: any channes in Section 3 must be initialed by your emnloyer.

Please enter or correct lhe following information.
1 SSN
2a. Name 2b. Former Name

Last First Ml (1fapplicable) Last First Ml
3. Permanent Address ~S"lce-,","A"dd",-es-,--------------"c";1y ___________ "si","1e

___ z",-,"c-od",------
MailingAddress
(If d1rrerent)
Street Address City State Zip Code
4. Telephone- Home~--~--------------- Telephone- Other~--~--------------

5. E-mail
SECTION 2: BORROWER'S CERTIFICATION REQUESTS, AUTHORIZATIONS, AND UNDERSTANDINGS
Before signing, carefully read the entire form, including the instructions and accompanying letter.
I request that the U.S. Department of Education (the Department} accept this Employment Certification from the public service
organization at which I am/was employed for purposes of qualifying for the Public Service Loan Forgiveness Program. If I submit
this form before I am eligible to apply for forgiveness, I request that the Department retain this original certification form until I
submit the Application for Public Service Loan Forgiveness.
I authorize my employer(s) or other entities having records about the employment that is part of the basis for my request for
forgiveness to make information from those records available to the Department, including my Direct Loan servicer. I also authorize
the U.S. Department of Education and its respective agents and contractors, to contact me regarding this Employment Certification,
at the current or any future number that I provide for my cellular telephone or other wireless device using automated telephone
dialing equipment or artificial or prerecorded voice or text messages.
I understand that:
(1) I may only qualify for Public Service Loan Forgiveness after I have made 120 separate, qualifying monthly payments on an
eligible Direct Loan, after October 1, 2007, while employed full-time by a public service organization{s), or serving in a full-time
AmeriCorps or Peace Corps position, in accordance with the definitions in Section 6. These 120 payments do not have to be
consecutive:
(2) I must be employed full-time by a public service organization(s) or serving in a full-time AmeriCorps or Peace Corps position at
the time I apply for loan forgiveness and at the time the forgiveness is granted. I may be employed part-time concurrently by
more than one eligible public service organization and meet the full-time requirement;
(3) Only the remaining balance of my loan{s) after I have made the 120 separate, qualifying monthly payments and met all other
eligibility requirements of the PSLF Program may be forgiven;
(4) I am not required to submit any Employment Certification{s) before applying for loan forgiveness, but ii I do, the Department will
review each Employment Certification I submit to ensure that it is complete, will verify that my employer qualifies as a public
service organization, and that the loan payments I made during the period covered by the Employment Certification(s) are
qualifying payments. Following this review, the Department will notify me in writing of the number of qualifying payments I have
made while employed in qualifying public service and the remaining number I must make before I am eligible to apply for PSLF.
I will also be notified in writing if the Department determines that the form(s) I submitted is incomplete or that my employment
does not meet the qualifying criteria under the regulations, including the reason(s) for the determination(s}, along with the steps I
would need to take to complete this form or correct this information: and
(5) The Department will only determine whether I have fulfilled all of the requirements to be eligible for PSLF after I have made all
120 qualifying payments and have submitted my loan forgiveness application. I understand that the law does not permit partial
forgiveness based on making a lesser number of qualifying monthly payments while working in qualifying public service.
Signature of Borrower Date (MM-DD-YYYY)
Page15of27
OBTAINEDBorrower
BY STUDENT BORROWER PROTECTION CENTER AND
Name. __________________ _
AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
Borrower SSN: I_I_I_I-I_I_I-I_I_I_I_I
SECTION 3: CERTIFICATION OF EMPLOYMENT An authorized official (see Section 5) of the public service
See Section 3 of the accornpany,ng Instructions for Complelmg Employment Cer/111cat,onfor Pub/1~ organization at which the borrower Is,was employed must
Service Loan Forgiveness for detailed ,nrormat,on on completing this section
complete this section
These Instructions are also located at www.studentrnd ed nov,xxxxxx/PSLF
.
Instructions for Authorized Official:
Complete this form only 1/you are an authorized off1c1alof the public service organization at which the borrower identified In Section 1 Is,was employed or, 1fthe
.. borrower ,s/was a rull-time AmeriCorps or Peace Corps volunteer, an authorized otricial of AmenCorps or the Peace Corps.
Read the definitions in Section 5 before completing this form .
. Type or print using blue or black ink. All fields must be completed if applicable. Your signature date must include month. day. and year (mm-dd-yyyy) .
Provide all requested 1nformat1onfor Items 1, 2, and 3 below. Complete the employer's cert1f1cat1on at the bottom of this page. The Employment Cert1ficat1onform
. cannot be processed ,r the information requested in this section is missing.

If you make any changes to the information you provide ,n this section. you must initial each change .
Please return the completed form to the borrower. The U.S. Department of Education or the Direct Loan servicer may contact you for additional 1nformat1onor
documentation.
.
Instructions for Borrower when there is no Authorized Official:
0 Check this box 1fyou are unable to obtain certification from an authorized official, for example. because the organization no longer exists. Provide all requested
1nformat1onfor Items 1 2 and 3 below For Item 1 11stthe organizat,on·s address from when you worked there, and consult your W2 records for the EIN The
Denartment w,1Irenu,re vou lo submit additional evidence of vour nual,f inn emnlovmenl. Do nol submit sunnortinn documents until renuested lo do so.
1. Information about the public service organization at which the borrower is/was employed.
Public Service Organization Name Federally Assigned Employer ID# (EIN)
Public Service Organization Address
2. Borrower's Employment Status.
,., Dates of employment: Start:

Date (MM-DD-YYYY)
End:
Date (MM-DD-YYYY)
(If the borrower Is still employed, put today's dale)
(b) Borrower"s employment status at your organization.
O Full-Time Average number of hours per week: ---
O Part-Time Average number of hours per week: ---
For purposes of eligibility for PSLF, full-time employment is defined as:

(1) Working In qual1fy1ng employment in one or more Jobs for the greater of:
(A} An annual average of at least 30 hours per week or. for a contractual or employment period of at least 8 months, an average of 30 hours per
week; or
(B} Unless the qualifying employment is with two or more employers, the number of hours the employer considers full-time.
(2) Vacation or leave time provided by the employer or leave taken for a condition that is a qualifying reason for leave under the Family and Medical
Leave Act of 1993, 29 U.S.C. 2612(al(1) and (3) does not affect employment status.
NOTE: A full-time AmeriCorps or Peace Corps volunteer is considered a full-time employee for eligibility purposes for PSLF.
,.,
3. Type of Public Service Organization,
0 A government organization
a Tribal college or university):
in accordance with the definition in Section 5 (check one):
(including a Federal, State, local or Tribal organization, agency or entity: a public child or family service agency: or
(b) □ A non-profit Section 501(c){3) organization:
,,, □ A private, non-profit organization' that provides at least one of the following public services (check all that apply}:
□ Emergency management,
□ Military service,
□ Public safety,
□ Law enforcement,
□ Public interest law services,
□ Early childhood education (including licensed or regulated child care. Head Start, and State funded pre-kindergarten),
□ Public service for individuals with disabilities and the elderly,
□ Public health (1nclud1ng nurses, nurse practItIoners, nurses In a clinical setting, and full-time professionals engaged In health care
practItIoner occupations and health support occupations, as such terms are defined by the Bureau ot Labor Statistics),
□ Public education.
□ Public library services,
□ School library services, or
□ Other school-based services.
'A private organization does not qualify 1fIt is (1) a for-profit business. {2) a labor union, or (3) a partisan political organization. Additionally,
rel1g1ous organization only qual1t1es it the borrower's job duties are unrelated to religious instruction, worship services, or proselytizing
•
I certify that the borrower identified In Section 1 above is/was employed at a public service organization. as indicated above. or is/was serving In an
AmeriCorps or Peace Corps position (in accordance with the def1nit1ons of these terms In Section 51during the period 1dent1fiedin Item 2(a) of this section.
Authorized otl1c1al's Name (Printed) Authorized Official's Tille
(__ )
Authorized Off1c1al's Signature Authorized Official's Telephone Today·s Date (mm-dd-yyyy)
SECTION 4: ELIGIBILITY REQUIREMENTS I TERMS AND CONDITIONS FOR PUBLIC SERVICE LOAN FORGIVENESS I
Page16of 27
You may obtain loan forgiveness under this program 1f.
(11 You are not ,n default on the loan(s) for which forgiveness is requested.
(21 Except as provided below for AmeriCorps and Peace Corps volunteers, you have made 120 separate, qualifymg monthly payments after October 1 2007, on the
Direct Loan(s) for which you are requesting forgiveness under one or more of the following repayment plans-
The Income-Based Repayment (IBR) Plan,
The Income Contingent Repayment (ICR) Plan;
The 10-Year Standard Repayment Plan' (Standard Repayment Plan with a maximum 10-year repayment period): or
Any other Direct Loan repayment plan, but only payments that are at least equal to the monthly payment amount that would be required under the Standard
Repayment Plan with a 10-year repayment period may be counted toward the required 120 payments.
In addition. each of the required 120 separate. qualifying monthly payments must have been made on time (no later than 15 days of the scheduled due date) and
for the full scheduled installment amount.
• IMPORTANT: The Standard Repayment Plan for Direct Consolidation Loans entered on or after July 1, 2006 have varying repayment terms based on the loan
amount. For purposes of qualifying for Public Service Loan Forgiveness, monthly payments you make under the Standard Repayment Plan on a Direct
Consol1dat1on Loan are only qualifying payments 1fmade under the 10-year repayment term.
Note for AmeriCorps/Peace Corps volunteers: If you were an AmenCorps or Peace Corps volunteer. you may receive credit for making qualifying payments ii
you make a lump sum payment on an eligible loan for which you are seeking forgiveness by using all or part of a Segal Education Award rece,ved after a year of
AmeriCorps service. or by usmg all or part of a Peace Corps transition payment (1fthe payment is made within 6 months after you leave the Peace Corps). The
Department will consider the lump sum payment you have made as the equivalent of qualifying payments equal to the lesser of.
(1) The number of payments resulting after dividing the amount or the lump sum payment by the monthly payment amount you would have made under one of
lhe qualily,ng repayment plans listed above: or
(2) Twelve payments.
Peace Corps volunteers making an eligible lump sum payment must do so w1th1n6 months of the End Date. as reported ,n Section 3 by the authorized off1c1al.
(31 You were/are employed full t,me by a public service organization(s) or serving in a full-lime AmenCorps or Peace Corps position at the time you made each of the
required 120 qualifying monthly payments, at the time you apply for loan forgiveness. and at the time loan forgiveness is granted.
NOTE: You are nol eligible to apply the same period of service lo receive a benefit under the PSLF Program and other Federal loan forgiveness or repayment
assistance programs including Teacher Loan Forgiveness. Service in Areas or National Need, and Civil Legal Assistance Attorney Student Loan Repayment.
You may not apply for PSLF until after you have met the eligibility requirements listed above. Since only qualifying payments made after October 1. 2007 while
providing qualifying service may be counted toward the required 120 payments, and borrowers may not apply for loan forgiveness until after they have made all 120
payments. the earliest date that any borrower will be eligible to apply for and receive loan forgiveness ,s October 2017. A PSLF Application will be made available to the
public before October 2017.
SECTION 5: DEFINITIONS
Eligible Loans
Loans that are eligible for Public Service Loan Forgiveness are:
• Federal Direct Staflord1Ford Loans (Direct Subsidized Loans)
• Federal Direct Unsubsidized Stafford/Ford Loans (Direct Unsubsidized Loans)
• Federal Direct PLUS Loans (Direct PLUS Loans)
• Federal Direct Consolidation Loans (Direct Consolidation Loans).
Loans that are m default are not eligible for forgiveness.
Note: Federal Family Education Loan (FFEL) Program loans. Federal Perkins Loans. and certain Health Professions and Nursing Loans may be consolidated
into a Direct Consolidation Loan. However, payments made on these loans pnor to consol1dat1on into the Direct Loan Program are not qualifying
payments and are not counted toward the required 120 payments for PSLF.
Qualifying Payments
• Separate. on-time, scheduled monthly payments made after October 1. 2007 under a qualifying Direct Loan repayment plan. A payment is considered on-
time ,fit is made for lhe full scheduled installment amount no later than 15 days of the due date for the payment.
• Qualifying Direct Loan repayment plans are:
The IBR Plan,
The ICR Plan:
The 10-Year Standard Repayment Plan (Standard Repayment Plan with a maximum 10-year repayment period): and
Any other Direct Loan repayment plan. but only payments that are at least equal to the monthly payment amount lhal would be required under lhe
Standard Repayment Plan with a 10-year repayment period may be counted toward the required 120 monthly payments.
Oual1fy1ng Employment
• AmeriCorps position means a position approved by the Corporation for National and Community Service under Section 123 of the National and
Community Service Act of 1990 (42 U.S.C. 12573).
• An authorized official is an official of a public service organization {1nclud1ngAmenCorps or the Peace Corps) who has access to the borrower's
employment or service records and is authori.:ed by the public service organi.at1on to certify the employment status of the organization's employees or
former employees, or the service of AmeriCorps or Peace Corps volunteers.
• An employee means an individual who ,s hired and pa,d by a public service organization.
• Full-time means working ,n qualifying employment ,none or more Jobs for the greater of.
• An annual average of at least 30 hours per week or. for a contractual or employment period of at least 8 months. an average of 30 hours per week: or
• Unless the qualifying employment is with two or more employers, the number of hours lhe employer considers full time.
Vacation or leave time provided by the employer or leave taken for a condition that is a qualifying reason for leave under the Family and Medical Leave Act
of 1993, 29. U.S.C. 2612(a)(1) and (3) does not affect employment status.
• Government employee means an individual who Is employed by a local, State. Federal, or Tribal government, but does not include a member of the U.S.
Congress.
• Law enforcement means service performed by an employee of a public service organi.at1on that Is publicly funded and whose principal activ1t1espertain to
crime prevention, control or reduction of crime, or the enforcement of criminal law.
• Military service for uniformed members of U S. Armed Forces or the National Guard means "active duty' service or "full-time National Guard duty' as
defined In Section 101(d)(1) and (d)(5) of Title 10 ,n the United States Code, but does not include active duty for training or attendance at a service
school. For c1v1l1ans.military service means service on behalf of the U S Armed Forces or the National Guard performed by an employee of a public
serv,ce organization.
Page17 of 27
■ Peace Corps position means a lull-time assignment under the Peace Corps Act as provided for under 22 U.S.C. 2504.
■ Public interest law refers to legal services provided by a public service organization that are funded m whole or in part by a local, State, Federal, or Tribal
government.
■ A public service organization is:
A Federal. State. local or Tribal government organization. agency or ent,ty;
A public child or family service agency:
A non-profit organization under Section 501 (C)(3) of the Internal Revenue Code that is exempt rrom taxation under Section 501 (a) of the Internal
Revenue Code:
A Tribal college or university: or
A private organization that provides at least one of the following public services and that ,snot a business organized ror profit, a labor union. a
partisan pol,t,cal organization. or an organization engaged ,n rel1g1ousact1v1t1es. unless the qualifying act,v,ties are unrelated to rel,g,ous ,nstruct,on,
worship services, or any form of proselytizing:
emergency management.
military service.
public safety,
law enforcement,
public interest law services,
early childhood education (including licensed or regulated child care. Head Start, and State funded pre-kindergarten),
public service for individuals with d1sabil1tiesand the elderly,
public health (including nurses, nurse practitmners, nurses in a clinical setting. and full-time professionals engaged in health care practitioner
occupations and health support occupations, as such terms are defined by the Bureau of Labor Statistics),
public education,
public library services.
school library services. or
other school-based services.
SECTION 6: WHERE TO SEND THE COMPLETED FORM

II you need help completmg th,s form, call.

Privacy Act Notice. The Privacy Act of 1974 (5 U.S.C. 552a) requires that the following notice be provided to you:
The authorities for collecting the requested ,nformat,on from and about you are §421 et seq .. §451 et seq ,§461 et seq and §420L et seq of the Higher Education Act or
1965, as amended (the HEA) (20 U.S.C. 1071 et seq., 20 U.S.C. 1087a et seq .. 20 U.S.C. 1087aa et seq .. and 20 U.S.C. 1070g et seq.) and the authorities for collecting
and using your Social Security Number (SSNJ are §§428B(f) and 484(a)(4) of the HEA 120 U.S.C. 1078·2(f) and 1091 (a)(4II and §3100111)11)of the Debt Collection
Improvement Act of 1996 (31 U.S.C. 7701 (c)). Participating in the William D. Ford Federal Direct Loan (Direct Loan) Program and giving us your SSN are voluntary. but
you must provide the requested ,nformat,on, including your SSN, to part1c1pate.
The principal purposes for collecting the 1nformat1onon this form, 1nclud1ngyour SSN, are to verify your 1dent1ty,to determine your el1g1b1l1ty to receive a Direct Loan, to
receive a benefit on a loan (such as a deferment. rorbearance, discharge. or rorg,veness), to permit the servicing of your loan(s). and, if it becomes necessary. to locate
you and to collect and report on your loan(s) ,f your loan ls) become delinquent or in default. We also use your SSN as an account 1dentif1erand to permit you lo access
your account 1nformat1onelectronically.
The informatmn in your file may be disclosed. on a case-by-case basis or under a computer matching program. to third parties as authorized under routine uses m the
appropriate systems of records notices.
For a loan. the routine uses of the information that we collect about you include. but are not limited to, its disclosure to federal, state, or local agencies. to institutions of
higher education. and to third party serv1cers to determine your el1g1b1lity
to receive a loan, to investigate possible fraud, and to verify compliance with federal student
financial aid program regulations.
In the event of lit,gat,on. we may send records to the Department of Justice. a court, ad1ud1cat1vebody, counsel. party, or witness if the disclosure ,s relevant and
necessary to the litigation. If this information. either alone or with other ,nformalion, indicates a potential violation of law. we may send il to the appropriate authority for
action. We may send information to members of Congress if you ask them to help you with federal student aid questions. In circumstances involving employment
complaints, grievances, or d1sc1pl1nary actions. we may disclose relevant records to ad1ud1cateor 1nvest1gatethe issues. If provided for by a collective bargaining
agreement, we may disclose records to a labor organization recognized under 5 U S.C Chapter 71 Disclosures may be made to our contractors for the purpose of
performing any programmatic function that requires disclosure of records. Before making any such disclosure, we w,11require the contractor to maintain Privacy Act
safeguards. Disclosures may also be made to qualified researchers under Privacy Act safeguards.
For a loan. the routine uses of this information also include. but are not limited to. its disclosure to federal, state. or local agencies. to private parties such as relatives,
present and former employers, business and personal associates, to creditors, to f1nanc1aland educational 1nst1tutions,and to guaranty agencies to verify your identity, to
determine your program el1g1bil1ty and benefits. to permit making. servicing, assigning, collecting, adJust,ng, or discharging your loan(s). to enforce the terms or the
loan ls). to investigate possible fraud and to verify compliance with federal student financial aid program regulations. to locate you if you become del,nquenl in your loan
payments or if you default. or to verify whether your debt qualifies for discharge or cancellation. To provide default rate calculations, disclosures may be made to
guaranty agencies, to f1nanc1aland educational 1nstitut1ons.or to federal. state or local agencies. To provide /1nanc1alaid history information, disclosures may be made to
educational institutions To ass,st program administrators with tracking refunds and cancellations. disclosures may be made to guaranty agencies, to financial and
educational institutions, or to federal or state agencies. To provide a standardized method for educational ,nslitutions to eff,cienlly submit student enrollment slalus.
disclosures may be made to guaranty agencies or to financial and educatmnal institutions. To counsel you m repayment efforts. disclosures may be made to guaranty
agencies, to financial and educational ,nst,tut,ons. or to federal. state, or local agencies.
Paperwork Reduction Notice According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of ,nformat,on unless ,t displays a
currently valid 0MB control number Public reporting burden for th,s collection or ,nformat,on ,s estimated to average X.X hours (XX minutes) per response. ,nclud,ng
lime for reviewing instructions. searching ex,sl,ng data resources. gathering and maintaining the data needed, and completing and review,ng the collection of information.
The obligation to respond to this collection is required to obtain a benefit m accordance with 34 CFR 685.219. Send comments regarding the burden estimate or any
other aspect of this collection of information, including suggestions for reducing this burden, to the U.S Department of Education. 400 Maryland Ave .. SW. Washington,
DC 2021 0-4537 or e-mail ICDocketMgr@ed gov and reference 0MB Control Number 1845-XXXX. Note: Please do not return the completed Employment
Certification for Public Service Loan Forgiveness to this address.
If you have comments or concerns regarding the status of your individual submission of this form, contact your Direct loan servicer (see Section 6).
Page18of 27
APPENDIXB
Instructions for Reviewing an Employment Certification form for PSLF (DRAFT)
Page19of 27
Instructions for Reviewing a PSLF Employment Certification form (ECF)
Part 1 Borrower submits PSLF Employment Certification form (pages 1-2, Sections 1-3 are required) to
PSLF Servicer
Servicer sends letter which:
A. Notifies the borrower that the ECF was received
B. Describes the initial review and interim validation process, including:

; Checking that the form is completely filled out
ii. Validating employer(s) as qualifying public service organization(s) and that the full-time
employment requirement was met
iii. Matching qualifying loan payments for that period of service
C. Includes the expected turnaround time for review (30-60 days). Additional time may be necessary if
information is missing or requires additional review by servicer or ED.
D. Informs the borrower of key program eligibility requirements and all necessary disclosures, including
roles and responsibilities of all entities involved
E. Acknowledges that servicer will retain submitted certifications on behalf of the borrower
Part 2 Servicer performs initial review to check for completeness.

STEP 1: Check that all REQUIRED information was provided:
1) Section 1: Information about the Borrower is complete (i.e., SSN, name)
2) Section 2: Borrower signed and dated the form
3) Section 3 (Employer):
i. (Item 1} Name, Address, EIN of the Organization is provided
ii. (Item 2a) Start Date and End Date provided
iii. (Item 2b) Full-time status checked. The average hours/week must be provided.
or Part-time status checked. The average hours/week must be provided.
iv. (Item 3) One box is checked (for a-c} under Type of Public Service Organization
• IF (c} is checked, one or more types of public services must be checked
v. Certification is completed, including the Authorized Official's Name, Title, Telephone
Number, Signature and Signature Date.
4) Section 3-Alternate: If the Borrower checks the box under Instructions for Borrower when there is
no Authorized Official at the top of Section 3, follow Step 1, Section 3(i-iv) above and request
additional documentation that supports the borrower's claim of qualifying employment.
STEP 2: If any information is altered, the Borrower or Employer, as appropriate, must have initialed next to
the change. If the Borrower or Employer has not initialed the alteration, return the form to the
borrower.
STEP 3: If information is missing:
1} You should attempt to obtain the missing information before returning the form to the borrower as
an incomplete form, by contacting the borrower or employer by telephone or e-mail.
2) If no telephone number or e-mail address was provided, or you have attempted without success
to reach the intended party, return the form to the borrower as incomplete. In the letter, indicate
specifically which information is missing and what the borrower must do in order for the servicer to
continue processing the form.
3) If a signature or signature date is missing in either Section 2 or 3, return the form to the Borrower.
Part 3. Verifvina aualifvina emplovment for PSLF

STEP 1: Check that the organization is listed on one of the provided directories for each category. If it is not
found there. escalate to the Department. (Mailbox will be provided by FSA)
• Federal, State, local or Tribal government organization, agency or entity:
http· Iiwww. usa .qov/Aqenci es. shim I
• Public child or family services agency {run by stateicountyicityitribal government)
Note: Child and family services agencies that are non-profit 501(c)3 organizations
(Category B) or private non-profit agencies (Category C) are also qualifying under
PSLF.
OBTAINED BY STUDENT BORROWER PROTECTION • CENTER
Tribal colleqe or university:
AND AMERICAN httn:/lwww2.ed.nov/aboul/inits/list/whtcledlite-tclist.html
FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
• Non-profit 501(c)3 organization: http://www.1rs.qoviapplpub-781 .

Helpful hints:
• For Organization Name, choose "Includes" in the dropdown menu .
• Search using the organization's full name and check "All of the words" to narrow
the search. If negative result, check the organization's acronym, or the name
exactly as written on the ECF.
• Use the organization's City and State, as provided on the ECF .
• A foreign entity that is registered with the IRS as a public non-profit organization
qualifies if it is found here. Select from the "Country"' dropdown box.
• Private organization providing public services:

• If this category is checked, first search the IRS database to see if it is actually listed as
having 501 (c)3 status.
• If NO, escalate to the Department for approval.
STEP 2: Check Full-Time status requirement {Section 3, Item 2b)
• If Full-Time is checked, hours must be 30 or greater. If YES, condition is met.
• If Part-Time is checked, the borrower must provide additional ECFs for concurrent periods of
employment for those months to be qualifying {hours may be less than or greater than 30).
• To calculate if two or more Part-Time positions meet the Full-time requirement:
a) The borrower must submit certifications from two or more part-time employers for which
the borrower concurrently worked.
b) Calculate the total average weekly hours worked, by adding the hours provided in
Section 3, Item 2b of each certification, next to Part-Time. If the sum of the average
hours is 30 or more, the definition of Full-time employee applies.
Example #1:
Employer 1: 20 hours per week during March-September 2011.
Emolo er 2: 10 hours oer week durina Janua -Julv 2011.
Jan. Feb. Mar. Apr. May Jun. Jul. Aug. Sep.
Emp.
20 20 20 20 20 20 20
1
Emp.
10 10 10 10 10 10 10
2
Total :,
C 30 so
hrs. 30 30
TOTAL= 30 hours per week for March-July 2011 {5 months)
At least 30 hours/week as required for 2 or more part-time employers?
YES=> Full-time requirement satisfied tor 5 months.
Proceed to matching months of qualifying employment with qualifying payments.
Example #2:
Employer 1: Part-time at 35 hours/week during February-July 2011 (6 months)
Employer 2: Part-time at 20 hours/week during August 2011-March 2012 (8 months)
Feb. Mar. ..pr. May Jun. Jul. Aug. Sep. Oct. Nov. Dec. ac. Feb. Mar.
Emp. 35 35 35 35 35 35
1
Emp.
2 20 20 20 20 20 20 20 20
Total
hrs.
Greater than 30 hours/week as required for 2 or more part-time employers?
NO=>Here the borrower is employed 35 hours/week from February-July but the employer
has Indicated that this Is not considered full-time. While the borrower has submitted ECFs
from 2 part-time employers, because these positions are not concurrent tor any given
calendar month, the Full-time requirement is not satisfied.
Page 21 of 27
Part 4. Conclude review and match aualifvina oavments with aualifvina emolovment
STEP 1: Once qualifying employment is established, determine if qualifying payments were made within this
period.
• Count each month from the Start Date to End Date, where a qualifying payment was made. For the
first month, the actual payment date must be on or after the Start Date. For the last month, the
actual payment date must be before the End Date of each Employment Certification. For Part-time
employees, these conditions apply to each employer.
• For partial payments made, the actual payment date is the date on which the total of partial
payments equals to or is greater than the full scheduled payment due amount for that month.
• The scheduled payment date will determine the calendar month for which the qualifying payment is
counted.
Example: Scheduled payment date is July 1 but actual payment date is June 29. Assuming
the borrower does not have previous delinquencies, the qualifyinq payment ap~ lies to July.
Part 5. Notification of Outcome
Send the Borrower a notification of the outcome of the review.

For PSLF qualifying employment, the notification should include the following:
• The borrower's loans will be transferred from the borrower's original servicer(s) for all federally held
loans.
• Number of qualifying payments made while employed in qualifying public service (matched months),
based on the dates indicated on the current certification(s)
• The total number of matched months the servicer has validated to date and the remaining number
required towards becoming eligible for PSLF
• Key reminders, including the following:
• Keeping copies of submitted forms and supporting documents
• Borrower must be employed in qualifying public service when applying for and receiving
forgiveness
• Borrower must apply for PSLF using an application provided by the Department after having
met the 120-month eligibility requirement
• No partial forgiveness is allowed based on making lesser than 120 qualifying payments
• To receive any forgiveness under the PSLF Program most of the loan payments must be made
under IBR or ICR to have any remaining loan balance after 120 payments have been made
If unable to validate PSLF qualifying employment, the notification should include the following:
• Identify the specific reason the ECF could not be approved at this time .
• Missing required information (specify)
• Unable to confirm employer is qualifying public service organization (can submit additional
evidence)
• Full-time requirement not met (will re-evaluate if additional ECF's are submitted for this period
of public service employment)
• Illegible (specify) or crossed out/altered information without initials of amender
• The borrower's federally held loans will remain with the borrower's original servicer until a valid
ECF is submitted.

forgiveness
under IBR or ICR to have anv remainino loan balance after 120 payments have been made
Part 6 Emolovment Certification from AmeriCoros and Peace Cores

STEP 1: Flag Employment Certifications received from borrowers who are/were AmeriCorps or Peace Corps
volunteers for lump sum payment exception.
• If an AmeriCorps or Peace Corps volunteer made qualifying payments during the period of service
these qualifying payments should be matched following normal procedures.
• If qualifying payments were not made during the period of service look for a lump sum payment.
Page 22 of 27
• If no lump sum was received contact the borrower reminding him/her that making a lump
sum payment from a Segal award or transition payment can be applied as PSLF-
• If a lump sum payment is received-from the National Service Trust for AmeriCorps, and
within 6 months of the End Date for Peace Corps-apply the lump sum as qualifying
payments, as allowed in the regulations.
STEP 2: Matching credited qualifying payments to AmeriCorps/Peace Corps service
Start from the last service month for which there is no corresponding qualifying payments and proceed
backwards up to 12 months.
Example: Borrower submits an ECF from the Peace Corps with service dates January 15, 2012-
November 30, 2013, during which time his Direct Loans were on a Peace Corps deferment.
Borrower submits a lump sum payment to servicer in the amount of $5000 (Note: only the maximum
transition award should be considered for this lump sum conversion-currently $7,425). Payment
was received January 10, 2013, within the allowed 60 days. The borrower's monthly payment would
have been $200.
$5000/$200= 25 months. Although the borrower was in service for 23 months, the maximum number
of qualifying payments (OPs) the borrower may receive credit for is 12.
These OPs match with 12 months of qualifying employment, starting with November 2013 to
December 2012. Use the 1st day of the month when recording credited OP date (e.g., 11/01/13,
10101/13, etc.). If a credit is applied to the Start Date month, use the Start Date (e.g. 01/15/12 if Start
month was one of the 12 credited OP months}.
~11an ECF is received with Peace Corps certification. do not reject for PSLF eligibility due to no QPs
until the 60-day window has expired.
Note on AmeriCorps Segal Awards:
AmeriCorps Segal Award payments do not have a 60-day from End Date payment requirement. A volunteer
has 7 vears after service to armlv Seaal Award.
Page 23 of 27
••• DEPARTMENT USE ONLY 0MB No. 1845-,xxx
Error! Objects ORIGINAL RECEIPT DATE: Form Approved
cannot be Employment Certification for Public Service Loan Forgiveness Exp Date xxixxixxxx
created from William D. Ford Federal Direct Loan Program ~------------~-----~
editing field WARNING: Any person who knowingly makes a false statement or misrepresentatmn on this form or on any accompanying documents is subject
codes. to penalties that may include fines. imprisonment. or both. under the U.S. Criminal Code and 20 U.S.C. 1097.

Read the accompanying instructions for completing lh1s Employment Certification for Public Service Loan Forgiveness. Type or print using blue or black ink. You
must sign and date this form m Section 2 and an authorized official from the public service organization which employsiemployed you must completely fill out.
sign, and date Section 3. II any information 1scrossed out or altered 1nSections 1 or 2, you must 1nit1albeside the change. any changes 1nSection 3 must be
in1t1aledb our emnlover.

Pleaseenter or correctthe followinginformation.
1 SSN REQUIRED
2a. Name REQUIRED _____ _ REQUIRED __ _ 2b. Former Name~------- ~-----

Last First Ml (ii applicable) Last First Ml
3. Permanent Address ~s",rn"e",

"Ad"o"rn"s",-------------- City
State Zip Code
Mailing Address
(if different)
Street Address City State Zip Code
4. Telephone- Home~--~--------------- Telephone- Other~--~--------------

5. E-mail
I request that the U.S. Department of Education (the Department} accept this Employment Certification from the public service
organization at which I am/was employed for purposes of qualifying for the Public Service Loan Forgiveness Program. If I submit
this form before I am eligible to apply for forgiveness, I request that the Department retain this original certification form until I
submit the Application for Public Service Loan Forgiveness.
forgiveness to make information from those records available to the Department, including my Direct Loan servicer. I also authorize
the U.S. Department of Education and its respective agents and contractors, to contact me regarding this Employment Certification,
at the current or any future number that I provide for my cellular telephone or other wireless device using automated telephone
dialing equipment or artificial or prerecorded voice or text messages.
I understand that:
(1) I may only qualify for Public Service Loan Forgiveness after I have made 120 separate, qualifying monthly payments on an
eligible Direct Loan, after October 1, 2007, while employed full-time by a public service organization{s), or serving in a full-time
AmeriCorps or Peace Corps position, in accordance with the definitions in Section 6. These 120 payments do not have to be
consecutive:
(3) Only the remaining balance of my loan{s) after I have made the 120 separate, qualifying monthly payments and met all other
eligibility requirements of the PSLF Program may be forgiven;
(4) I am not required to submit any Employment Certification{s) before applying for loan forgiveness, but ii I do, the Department will
review each Employment Certification I submit to ensure that it is complete, will verify that my employer qualifies as a public
service organization. and that the loan payments I made during the period covered by the Employment Certification(s) are
qualifying payments. Following this review, the Department will notify me in writing of the number of qualifying payments I have
made while employed in qualifying public service and the remaining number I must make before I am eligible to apply for PSLF.
I will also be notified in writing if the Department determines that the form(s) I submitted is incomplete or that my employment
does not meet the qualifying criteria under the regulations, including the reason(s) for the determination(s), along with the steps I
would need to take to complete this form or correct this information; and
120 qualifying payments and have submitted my loan forgiveness application. I understand that the law does not permit partial
forgiveness based on making a lesser number of qualifying monthly payments while working in qualifying public service.
REQUIRED REQUIRED
Signature of Borrower Date (MM-DD-YYYY)
Page 24 of 27
OBTAINEDBorrower
BY STUDENT BORROWER PROTECTION CENTER AND
Name. __________________ _
Borrower SSN: I_I_I_I-I_I_I-I_I_I_I_I

An authorized official (see Section 51 of lhe public service
See Section 3 of the accompanying Instructions tor Completmg Employment CerMcat1on tor Public
organization at which the borrower is/was employed must
Serv,c" Loan Forg,vc!ness for detailed information on completing this section
complete this section.
These lns/ruct,ons are also located al www studenta,d.ed ~ovlxxxxxxiPSLF
.
Instructions for Authorizc!d Official:
Complete this form only 1f you are an authorized official of the public service organization at which the borrower identified in Section 1 islwas employed or, if the
.. borrower Isiwas a full-time AmeriCorps or Peace Corps volunteer, an authon.:ed official of AmenCorps or the Peace Corps.
Read the def1n1tions,n Section 5 before completing this form
. Type or print us,ng blue or black ink. All fields must be completed ii applicable. Your s,gnalure date must include month. day. and year (mm-dd-yyyy) .
Provide all requested information for Items 1, 2, and 3 below. Complete the employer's certification at the bottom of this page. The Employment Certification form
. cannot be processed if the 1nformat1onrequested ,n this section is missing.

Ir you make any changes to the ,nrormation you provide ,n this section, you must ,n,t,al each change
Please return the completed form to the borrower. The U.S. Department of Education or the Direct Loan servicer may contact you for additional information or
documentation.
.
Instructions lor Borrower when there is no Authorized Official: ,:If this box Is checked Items 1 2 3 REQUIRED except Authorized Off1c1als cerllf1cat1onat bottom of 3)
D Check this box ii you are unable to obtain cerlif,calion from an authorized official. for example. because lhe organization no longer exists. Provide all requested
information for Items 1 2. and 3 below. For Item 1 list the organization's address from when you worked there, and consult your W2 records for the EIN The
,. Deoartment will reauire vou to submit additional evidence of vour aualif ma emolovment. Do not submit suooortina documents until reouested to do so.
Information about the public service organization at which the borrower is/was employed.
REQUIRED -- REQUIRED
Public Service Organization Name Federally Assigned Employer ID# (EIN)
REQUIRED
(a) Dates of employment: Slarl: --- Hl::OlJIHl::lJ --- End: - Hl::UlJIHl::lJ --- (If the borrower is st,II employed. put today"s date)
Dale (MM-DD-YYYY) Date (MM-DD-YYYY)
(b) Borrower's employment status at your organization REQUIRED (drnc< c11ebox Hild provide hcurs)
D Full-Time Average number of hours per week: ---
D Part-Time Average number of hours per week. ---
,,,
For purposes of eligibility for PSLF. full-time employment is defined as:
Working ,n qualifying employment in one or more jobs for the greater of:
(A) An annual average of at least 30 hours per week or. for a contractual or employment period of at least 8 months. an average of 30 hours per week: or
(B) Unless the qualifying employment Is with two or more employers. the number of hours the employer considers full-time.
(2) Vacation or leave time provided by the employer or leave taken ror a cond1t1onthat ,s a qualifying reason ror leave under the Family and Medical Leave Act of
1993. 29 U.S.C. 2612(a)(1 I and (3) does not affect employment status.
NOTE: A full-time AmenCorps or Peace Corps volunteer Is considered a full-time employee for el1g1bil1typurposes for PSLF.
3. Type of Public Service Organization, in accordance with the definition in Section 5 (check one): REQUIRED
(d) D A government organization (,nclud,ng a Federal. State. local or Tribal organizat,on. agency or ent,ty: a public child or family service agency: or a Tribal
college or un1vers1ty)
,., D A non-prolit Section 501 (c)(3) organization:
(I) D A private, non-profit organization' that provides at least one of the following public services (check all that apply): REQUIRED ,:,f 3c cl'ecked:,
D Emergency management,
D Military service.
D Public safety,
D Law enforcement,
D Public ,nteresl law services.
D Early childhood education (including licensed or regulated child care. Head Start. and State funded pre-kindergarten).
D Public service for individuals with d1sabil1t1esand the elderly,
D Public health (1nclud1ngnurses, nurse practitioners, nurses ,n a clinical setting. and rull-t,me professionals engaged ,n health care pract,t,oner
occupations and health support occupations. as such terms are defined by the Bureau of Labor Statistics).
D Public education.
D Public library services.
D School library services, or
D Other school-based services
·A private organization does not qualify if ,tis (1) a for-prol,t business. (2) a labor union. or (31 a partisan political organization. Additionally. a religious
organization only qualifies if the borrower's Job duties are unrelated to rel1gmus instruction. worship services. or proselytizing.
I certify that the borrower 1dentif1ed,n Section 1 above ,s/was employed at a public service organization. as 1nd1catedabove, or islwas serving ,nan AmeriCorps or Peace
Corps position (in accordance with the definitions of these terms in Section 5) during the period ,denlif,ed in Item 2(a) of this section.
REQUIRED REQUIRED
Authorized Off1c1al'sName (Printed) Authorized Of11c1aI·s
Title
Hl::OUlfll::lJ
Authonzed Oflic1al's S1anature
,__ )__ Hl::OUlfll::lJ
Authorized Official's Telephone
Hl::OUlfll::lJ
Todav's Date (mm-dd-"~
Page25 of 27
APPENDIXC
SAMPLEPSLF REPORT
Page26of 27
rear
2n12
"' '-" ...."'
I\)~ o~ Month
"'
~~ 0, ---J I\) ~
# of Borrowers
Returning ECF
# of Borrowers with
Approved ECF
# of Borrowers with
Disapproved ECF
# of Borrowers in
•
Government
Public, Non-Profit mm ..
~ Q s.
Private, Non-Profit
~a)::,
CD :, "O
~ CD"O
~ ~
--i ., 0
AmeriCorps ;§
CD'<
C" iii
C.
Peace Corps
i
"s
10-Year Standard ..-
0
" ICR :0"0►

CD"O
"O ~
IBR "' <
'< 0
3~
Equal to 10-Year CD [IJ
Standard ao
"U :::
-o
Consolidation
Standard, Not Equal
"' "
::, CD
o!
C"
to 10-Year Standard '<
" ..
0-24 Months
25-48 Months --
-·
::r ►
0
49-72 Months ;:aoo

"' CD
-
;:: "O
"' "O
<
::r CD
~
~~ a. a.
CD S: [IJ
73-96 Months oo
::, :::
-o
i;f "
-· CD
97-120 Months ::, o!
Public Service Loan Forgiveness

Standard ECF Review Process
A. Government Employer Qualification Review

1. Google for organization website
2. If domain is .gov, or .mil, approve
3. If it is a public school, approve 1
4. If a military branch, approve (Army, Navy, Air Force, Marines, Coast Guard, state national
guard)
5. If domain is not .gov, or .mil, search state and/or local government websites
6. Check EMMA (Electronic Municipal Market Access) database- if listed, approve
7. Quasi-government: Follow process above, then steps 1. - 3. under Private Not-for Profit
8. If not able to locate, deny
B. 501 (c)(3) Employer Qualification Review

1. Check IRS Publication 78: If listed, approve
2. If not in Pub 78, check IRS Business Master File: If listed and subsection code is 3, approve
3. Because religious entities may self-certify as a 501(c)(3), and therefore may not be listed on
IRS Pub. 78 or in IRS Business Master File even if qualified, all religious entities certifying as
a 501(c)(3) on the ECF should be approved unless clearly erroneous
4. If not found in either list, deny
C. Private Not-for-Profit Employer Qualification Review

1. Check SEC/EDGAR database: If found, deny as publically-traded for-profit business
2. Check state Corporation Bureau or Secretary of State database for the state of the employer
address on the ECF: If listed as NFP, accept, otherwise, deny
3. Google for website:
i. If no exact match, deny
ii. If exact match found and website clearly indicates qualifying not-for-profit status,
approve
D. Qualifying Employer Review/ "Second Look" Process

1. Request additional documentation of employer's qualifying NFP status. 2 Examples:
i. Documentation of NFP status from federal or state government or regulatory/ taxing
body (letter, reference to online database, etc.)
ii. Certificate of incorporation /charter
iii. Implementing legislation
2. Suggest requesting such documentation with submission of ECF to expedite review.
3. Deny if documentation is not provided or is not dispositive
E. Treatment of Incomplete ECF Data
1. Section 1: Borrower Information: Deny in all cases with following exceptions:

a. Missing Middle Initial
1 Public schools may have .org domains; .edu may be NFP or for-profit entities
< Financial data may be redacted.
b. Missing Prior Name

c. Missing Email
d. Missing (i) City and/or State or (ii) Zip Code AND address can be verified through data
provided (Street Address, City, State or Zip Code)
e. Missing Alternative Address
f. Missing Other Telephone
g. Telephone listed as NIA
h. Make borrower contact attempt to obtain required information prior to denial
2. Section 2: Borrower Certification: Deny if not both signed and dated by borrower
3. Section 3: Employer Information

a. Item 1 (Entity Name, EIN, Address): Deny if any field is not complete
b. Item 2 (Borrower Employment Status): Deny if any field is not complete
c. Item 3 (Type of Public Service Organization): Deny 3
d. Make 1 attempt to contact employer to obtain required information prior to denial
4. Section 3: Employer Certification - Deny if any field is not completed on the ECF
a. Certifying official name, title and signature must be included;
b. Authority of Authorized Official will be deemed self-certifying unless except where the
borrower signs as the Authorized Official
c. Employer certification must be completed on the ECF
F. Treatment of Erroneous or Conflicting ECF Data
1. Section 1: Borrower Information

a. Name Discrepancy: Accept minor variations (e.g., Kim/Kym, Mike/Michael) or if NSLDS
matching criteria are met; deny for all other discrepancies
b. Address or Telephone: Accept; resolve discrepancies upon conversion
c. Email: Accept; resolve discrepancies upon conversion
d. SSN: Deny if SSN provided does not match NSLDS or servicing system
e. Make borrower contact attempt to obtain required information prior to denial
2. Section 2: Borrower Certification: See E.2, above.

a. Item 1 (Entity Name, EIN, address)
i. Deny if name and EIN do not match
ii. Accept if Entity Name and EIN are verified without regard to address
b. Item 2 (Borrower's Employment Status): Deny if hours listed do not meet status minimum
(e.g., FT and 20 hrs/wk); otherwise, accept based on status checked (e.g., PT and 35 hrs/wk)
c. Item 3 (Type of Public Service Org.): Deny4
d. Make 1 attempt to contact employer to resolve conflict prior to denial
G. Miscellaneous
1. Religious Employment - Always approve based on hours certified on revised ECF if certified by
employer; we will not make value judgments as to the nature of the individual's employment
2. Alternative Employer Certification Documentation - Suggest that all certification information be

provided on ECF.
a. When incomplete alternative documentation is submitted, FSA suggests including a letter to
the employer with the rejection notice which directs them to the employer section of Q&As
3Failure to certify NFP status nullifies the certification

4
Failure to certify NFP status nullifies the certification. We will make efforts to tailor denial letters, e.g., "your
employer does not appear to qualify as a public service employer on the basis marked on your ECF. Please review
and provide additional information if you believe our determination to be in error."
(pp. 20-22) and provides a customer service contact number. The message to the employer
should be that the form is required. PHEAA will have to determine when alternative
documentation would be acceptable.
b. As an exception (or last alternative to receiving an ECF) and at PHEAA 's discretion, if the
borrower is still unable to obtain certification on the ECF but employer is willing to generate
an automated certification, provide guidelines for acceptable alternative certification:
• The documentation is produced directly by the employer or by an entity under
contract with the employer to perform employment certifications;
• The documentation (e.g., letter, printout) contains all employment-related
information necessary to support PSLFeligibility, which includes:
• Name of Organization;
• EIN of Organization;
• Address of Organization;
• Full-Time/Part-Time Status of the employee; and
• Dates of Employment of the employee.
• The documentation is signed and dated by an authorized official of the borrower's
employer; and;
• The documentation provides contact information for the authorized official.
3. Treatment of "Self-Certification - Self-certification is permitted if the borrower is the sole

authorized official of an active organization.
a. Reject ECF for no authorized official (FSA 05/10/12)
b. Make (b)(7J(El o contact borrower to inquire if another official may certify; if not:
c. Solicihoornornm,b evidence to verify employment period and work status:
Examples include W2s (required) & paystubs. If paystubs are not provided, verify if income from W2
reasonably supports hours worked for the period of employment.
4. No Authorized Official- This pertains to closed organizations. If this box is checked, all
information in Section 3 must be provided except for certification by employer. Borrower must
submit documentation that supports information provided in Items 2 and 3.
a. Item 2: solicit supporting evidence to verify employment period and FT/PT status, as
reported in Items 2a and 2b.
i. Examples include W2s (required) & paystubs. If paystubs are not provided,
verify that income from W2 reasonably supports hours worked for the period
of employment.
b. For organizations assumed to be defunct. Follow normal review process to confirm
this, then:
i. If 501 (c)3-check Pub 78's list of Recent Revocationsof 501(c)(3) Determinations
and the Auto Revocation List.
1. If qualifying status can't be confirmed, or for private not-for-profits,
follow "second look" procedures
2. If insufficient evidence is supplied by the borrower, Deny.
H. Examples
1. Employer is U.S. Air Force - EIN is not provided and type of public service organization is not
checked. Address is confirmed by web search as Air Force base.
a. Unable to obtain EIN on employer call. Deny
b. EIN obtained on employer call. Accept
2. Employer is "ABC Foundation" - EIN is provided, but type of public service organization is not
checked. EIN verified as a 501(c)(3) on IRS Pub 78. Accept
3. Employer indicates 501 (c)(3) - EIN not provided, but type of public service organization is
checked (item 3 box b). Employer verified as a 501(c)(3) through name/address on IRS Pub 78.
a. Unable to obtain EIN on call. Deny
b. EIN confirmed on call. Accept
checked (item 3 box b). Employer cannot be verified through name/address on IRS Pub 78.
Deny
Instructions CENTER
OBTAINED BY STUDENT BORROWER PROTECTION for Reviewing a PSLF Employment
AND AMERICAN FEDERATIONCertification
OF TEACHERS form UNDER
(ECF) THE FREEDOM OF INFORMATION ACT
Revised 12/07/2011
Part 1 Borrower submits PSLF Employment Certification form (pages 1-2, Sections 1-3 are required) to
PSLF Servicer
Servicer sends letter which:
A. Notifies the borrower that the ECF was received
B. Describes the initial review and interim validation process, including:

L Checking that the form is completely filled out
ii. Validating employer{s) as qualifying public service organization(s) and that the full-time
employment requirement was met
iii. Matching qualifying loan payments for that period of service
C. Includes the expected turnaround time for review (30-60 days). Additional time may be necessary if
information is missing or requires additional review by servicer or ED.
D. Informs the borrower of key program eligibility requirements and all necessary disclosures, including
roles and responsibilities of all entities involved
E. Acknowledges that servicer will retain submitted certifications on behalf of the borrower
Part 2 Servicer performs initial review to check for completeness.

STEP 1. Check that all REQUIRED information was provided:
1) Section 1: Information about the Borrower is complete (i.e., SSN, name, DOB)
2) Section 2: Borrower signed and dated the form
3) Section 3 (Employer):
i. {Item 1) Name, Address, EIN of the Organization is provided
ii. {Item 2a) Start Date and End Date provided
iii. {Item 2b) Full-time status checked. The average hours/week must be provided; or
Part-time status checked. The average hours/week must be provided.
iv. {Item 3) One box is checked (for a-c) under Type of Public Service Organization
• IF (c) is checked, one or more types of public services must be checked
v. Certification is completed, including the Authorized Official's Name, Title, Telephone
Number, Signature and Signature Date.
4) Section 3-Alternate: If the Borrower checks the box under Instructions for Borrower when there is
no Authorized Official at the top of Section 3, follow Step 1, Section 3 (i-iv) above and request
additional documentation that supports the borrower's claim of qualifying employment. The
Borrower must provide sufficient evidence that:
a) the Employer was a qualifying public service organization
b) the Borrower was engaged in paid employment for the indicated time period
c) the Borrower was employed In a full-tIme/part-tIme posItIon, as indicated on the ECF
STEP 2: If any information is altered, the Borrower or Employer, as appropriate, must have initialed next to
the change. If the Borrower or Employer has not initialed the alteration, return the form to the
borrower.
STEP 3: If information is missing:
1) You should attempt to obtain the missing information before returning the form to the borrower as
an incomplete form, by contacting the borrower or employer by telephone or e-mail.
2) If no telephone number or e-mail address was provided, or you have attempted without success
to reach the intended party, return the form to the borrower as incomplete. In the letter, indicate
specifically which information is missing and what the borrower must do in order for the servicer to
continue processing the form.
3) If a signature or signature date is missing in either Section 2 or 3, return the form to the Borrower.
Part 3. Verifvina aualifvina emolovment for PSLF
STEP 1. Check that the organization is listed on one of the provided directories for each category. If it is not
found there, escalate to the Department at publ1cserv1ce@ed.gov
• (a) Federal, State, local or Tribal government organization, agency or entity:

http://www. usa.gov/ Agencies.shtml
• Public child or family services agency (run by state/county/city/tribal government)
• Tribal college or university: httQ://www2.ed.gov/abouUinits/list/whtc/edl1te-tcl1st.html
Helpful hints
If the Federal/state/local/tribal government organization is not listed under the relevant
government Web site/directory, the Servicer should attempt to confirm this by
contacting the employer at the telephone number provided If this is unsuccessful, the
borrower may provide supporting evidence such as pay stubs, which IndIcate that they
are paid by a government entity
• (b) Non-profit 501(c)3 organization:

1) Download the IRS Publication 78 with EIN codes file httQ.llwww.irs.gov/Qub/irs-
soi/eoQub78ein.ziQ
2) Ensure you are using the most current version of this database by checking
htlQ://www.1rs.gov/taxstats/charitablestats/art1cle/0,,1d=97186,00.html. The date of the last
update should be no more than 30 days from the date of use unless a more recent version
IS unavailable.
3) In addItIon to Publication 78. the Business Master File (BMF) Is available for download at
the above link (by state or region) This file contains information on all tax exempt
organizations (not limited to 501(c)3s), including EIN, street address, class1ficat1oncodes
(e.g. religious, scientific, etc.), and group/parent codes. Inclusion in the BMF does not
necessitate that an organization Is qualifying for PSLF purposes but may be helpful for
research purposes
Helpful hints:
• Search first using the Organization's EIN
• If the Organization's Name does not match with what is listed in the database for
the provided EIN, contact the employer for conf1rmat1on.
• A foreign entity that is registered with the IRS as a public non-profit organization
qualifies if ii is found here.
• (c) Private organization providing public services:

• If this category is checked, first search the IRS database to see if ii is actually listed as
having 501 (c)3 status.
• If NO, escalate to the Department for approval .
STEP 2: Check Full-Time status requirement (Section 3, Item 2b)
• If Full-Time is checked, hours must be 30 or greater. If YES, condition is met.
• If Part-Time is checked, the borrower must provide additional ECFs for concurrent periods of
employment for those months to be qualifying {hours may be less than or greater than 30).
• To calculate if two or more Part-Time positions meet the Full-time requirement:
a) The borrower must submit certifications from two or more part-time employers for which
the borrower concurrently worked.
b) Calculate the total average weekly hours worked, by adding the hours provided in
Section 3, Item 2b of each certification, next to Part-Time. If the sum of the average
hours is 30 or more, the definition of Full-time employee applies.
Example #1:
Employer 1: 20 hours per week during March-September 2011.
Emolo er 2: 10 hours per week durinq Janua "-Julv 2011.
Jan. Feb. Mar. Apr. May Jun. Jul. Aug. Sep.
Emp.
1 20 20 20 20 20 20 20
Emp.
10 10 10 10 10 10 10
2
Total
hrs.
C 30 30 30 30
TOTAL= 30 hours per week for March-July 2011 (5 months)

30
"
At least 30 hours/week as required for 2 or more part-time employers?
YES=>
OBTAINED BY STUDENT BORROWER Full-time CENTER
PROTECTION reauirement satisfied for
AND AMERICAN 5 months. OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
FEDERATION
Page2of7
Proceed to matching months of qualifying employment with qualifying payments.
Example #2:
Employer 1: Part-time at 35 hours/week during February-July 2011 (6 months)
Employer 2: Part-time at 20 hours/week during August 2011-March 2012 (8 months)
Feb. Mar. Apr. May Jun. Jul. Aug. Sep. Oct. Nov. Dec. Jan. Feb. Mar.
Emp.
35 35 35 35 35 35
1
Emp.
20 20 20 20 20 20 20 20
2
Total
hrs.
Greater than 30 hours/week as required for 2 or more part-time employers?
NO=>Here the borrower is employed 35 hours/week from February-July but the employer
has indicated that this is not considered full-time. While the borrower has submitted ECFs
from 2 part-time employers, because these positions are not concurrent for any given
calendar month, the Full-time requirement is not satisfied.
Part 4. Conclude review and match ciualifvin~ payments with ciualifvin~ employment
STEP 1: Once qualifying employment is established, determine 1fqualifying payments were made wIthIn this
period.
• Count each month from the Start Date to End Date, where a qualifying payment was made. For the
first month, the actual payment date must be on or after the Start Date. For the last month, the
actual payment date must be before the End Date of each Employment Certification. For Part-time
employees, these conditions apply to each employer.
• For partial payments made, the actual payment date Is the date on which the total of partial
payments equals to or is greater than the full scheduled payment due amount for that month.
• The scheduled payment date will determine the calendar month for which the qualifying payment is
counted.
Example: Scheduled payment date is July 1 but actual payment date is June 29. Assuming
the borrower does not have nrevious delinnuencies, the nualifvino navment anrlies to Julv.
Page3of7
Part 5. Notification of Outcome
Send the Borrower a notification of the outcome of the review.

For PSLF qualifying employment. the notification should include the following:
• The borrower's loans will be transferred from the borrower's original servicer{s) for all federally held
loans.
• Number of qualifying payments made while employed in qualifying public service (matched months),
based on the dates indicated on the current certification(s)
• The total number of matched months the servicer has validated to date and the remaining number
required towards becoming eligible for PSLF
forgiveness
• The 120 payments must be separate, on-time, full monthly payments. Prepayments generally
will not count toward more than one qualifying payment
under IBR or ICR to have any remaining loan balance after 120 payments have been made,
although the Borrower will pay more interest over time 11the Borrower does not ultimately
qualify for PSLF
If unable to validate PSLF qualifying employment, the notification should include the following:
• Identify the specific reason the ECF could not be approved at this time .
• Missing required information {specify)
• Unable to confirm employer is qualifying public service organization {can submit additional
evidence)
• Full-time requirement not met (will re-evaluate if additional ECF's are submitted for this period
of public service employment)
• Illegible (specify) or crossed ouUaltered information without initials of amender
• The borrower's federally held loans will remain with the borrower's original servicer until a valid
ECF is submitted.

forgiveness
under IBR or ICR to have anv remaininq loan balance after 120 pavments have been made
Page4 of 7
Part 6 Emolovment Certification from AmeriCoros and Peace Coros
STEP 1: Flag Employment Certifications received from borrowers who are/were AmeriCorps or Peace Corps
volunteers for lump sum payment exception.
• If an AmeriCorps or Peace Corps volunteer made qualifying payments during the period of service
these qualifying payments should be matched following normal procedures.
• If qualifying payments were not made during the period of service look for a lump sum payment.
• If no lump sum was received contact the borrower reminding him/her that making a lump
sum payment from a Segal award or transition payment can be applied as PSLF qualifying
payments.
• If a lump sum payment Is received (for AmerICorps-from the National Service Trust; for
Peace Corps-directly from the Borrower and wIthIn 6 months of the End Date of service),
apply the lump sum as qualifying payments, as allowed in the regulations.
STEP 2: Matching credited qualifying payments to AmeriCorps/Peace Corps service
Start from the last service month for which there is no corresponding qualifying payments and proceed
backwards up to 12 months.
Example:
• Borrower submits an ECF from the Peace Corps with service dates January 15, 2012-
November 30, 2013, during which time his Direct Loans were on a Peace Corps deferment.
• Borrower submits a lump sum payment to servicer in the amount of $5000 {Note: only the
maximum transition award should be considered for this lump sum conversion-currently
$7,425). Payment was received January 10. 2014. within the allowed 6 months from the End
Date of service. The borrower's monthly payment would have been $200.
• $5000/$200= 25 months. Although the borrower was in service for 23 months, the maximum
number of qualifying payments (QPs) the borrower may receive credit for is 12.
• These QPs match with 12 months of qualifying employment, starting with November 2013 to
December 2012. Use the 1st day of the month when recording credited OP date (e.g.,
11/01/13, 10/01/13, etc.). If a credit is applied to the Start Date month, use the Start Date
{e.g. 01/15/12 if Start month was one of the 12 credited OP months).
*If an ECF is received with Peace Corps certification, do not reject for PSLF eligibility due to no QPs until the
6 month window has expired.
Note on AmeriCorps Segal Awards:

AmeriCorps Segal Award payments do not have a 6-month from End Date payment requirement. A volunteer
has 7 vears after service to a""i" Seoal Award.
Page5of7
••• DEPARTMENT USE ONLY 0MB No. 1845-xxx,
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS
***ORIGINAL UNDER
RECEIPT THE FREEDOM
DATE: OF INFORMATION ACT
Form Approved
Employment Certification for Public Service Loan Forgiveness (PSLF)

William D. Ford Federal Direct Loan Program
WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on any accompanying documents 1s
subject to penalties that may include fines, imprisonment, or both, under the U.S. Criminal Code and 20 U.S.C. 1097.

Read the accompanying instructions for completing this Employment Cert1f1cat1onfor Public Service Loan Forgiveness. Type or print using blue
or black ink. You must sign and date this form 1nSection 2 and an authorized off1c1alfrom the public service organization which
employs/employed you must completely fill out, sign, and date Section 3. If any information is crossed out or altered in Sections 1 or 2, you
must initial beside the chan e; an chan es in Section 3 must be initialed b our em lo er.
Please enter or correct the following information. D Check this box if any of your information has changed
1a. SSN .LLJ REQUIRED 1b. Dale of Birth (mm-dd-yyyy) _ REQUIRED_____ _
2a. Name ___ REQUIRED____ _ REQUIRED__ _ 2b. Former Name _______________ _

Last First Ml (if applicable) Last First Ml
3.PermanentAddress ---~s,",-e"CA"c"o"rn-,-,--- city Slate Zip Code
Mailing Address
(1fdifferent) Street Address City State Zip Code
4 Area Code/Telephone- Home~--~--------- Area Code/Telephone- Other
5. E-mail (optional)
I request that the Public Service Loan Forgiveness servicer, on behalf of the U.S. Department of Education (the Department),
accept this Employment Certification from the public service organization at which I am/was employed for purposes of qualifying
me for the Public Service Loan Forgiveness Program. If I submit this form before I am eligible to apply for forgiveness, I request
that the PSLF servicer retain this certification form until I submit the Application for Public Service Loan Forgiveness.
forgiveness to make information from those records available to the Department, including the Public Service Loan Forgiveness
servicer. I also authorize the Department and its respective agents and contractors, to contact me regarding this Employment
Certification. at the current or any future number that I provide for my cellular telephone or other wireless device using automated
telephone dialing equipment or artificial or prerecorded voice or text messages.
I understand that:
(1) I may only qualify for Public Service Loan Forgiveness after I have made 120 separate, on-time, qualifying monthly payments
on an eligible Direct Loan, after October 1, 2007, while employed full-time by a public service organization(s), or serving in a
full-time AmeriCorps or Peace Corps position, in accordance with the definitions in Section 5. These 120 payments do not
have to be consecutive;
(3) Only the remaining balance of my loan(s) after I have made the 120 separate. on-time. qualifying monthly payments and met
all other eligibility requirements of the PSLF Program may be forgiven;
(4) I am not required to submit any Employment Certification(s) before applying for loan forgiveness, but if I do, the PSLF servicer
will review each Employment Certification I submit to ensure that it is complete, will verify that my employer qualifies as a
public service organization, and that the loan payments I made during the period covered by the Employment Certification(s)
are qualifying payments. Following this review, the PSLF servicer will notify me in writing or electronically of the number of
qualifying payments I have made while employed in qualifying public service and the remaining number I must make before I
am eligible to apply for PSLF. I will also be notified in writing or electronically if the PSLF servicer determines that the form(s) I
submitted is incomplete or that my employment does not meet the qualifying criteria, including the reason(s) for the
determ1nation(s), along with the steps I would need to take to complete this form. correct this information. and submit the
corrected or additional information to the PSLF servicer; and
120 qualifying payments and have submitted my loan forgiveness application. I understand that the law does not permit
partial forgiveness based on making a lesser number of qualifying monthly payments while working at a qualifying public
Signature of Borrower REQUIRED Date (MM-0D-YYYY) REQUIRED
Page6of7
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER
Borrower THE
SSN: I FREEDOM
I I ,_, I OF
,_, INFORMATION
I I I I ACT
Borrower Name:
SECTION 3: CERT/FICA TION OF EMPLOYMENT An authorized official (see Section 5) of the public service
See Section 3 of the accompanying lns/ruct1ons for Completmg Employment Certification for Public organization at which the borrower is/was employed must
Service Loan Forgiveness for detailed information on completing this section.
complete this section
These Ins/ructions are also located at www studentaid.ed.~ov/ ublicservice
.
Instructions for Authorized Official:
Complete this form only 1fyou are an authorized official of the public service organization at which the borrower 1dentif1edin Section 1 is/was employed or, if the
borrower is/was a full-time AmeriCorps or Peace Corps volunteer, an authorized official of AmeriCorps or the Peace Corps.
. Read the definitions in Section S before completing this form .
.
. Type or print using blue or black ink. All fields must be completed if applicable Your signature date must include month, day, and year (mm-dd-yyyy).
Provide all requested information for Items 1 2. and 3 below Complete the employer's certification al the bottom of this page The Employment Certification form
. cannot be processed if the information requested in this section is missing.

If you make any changes to the information you provide in this section, you must initial each change .
Please return the completed form to the borrower. The U.S. Department of Education or the PSLF servicer may contact you for additional information or
documentation.
.
Instructions for Borrower when there is no Authorized Official:llf tr,~ box ,~ checked Iterns 1 2 3 REQUIRED. except Aullmri,:ed 0II,c,al s ccrt1f1cc1t1on at bottom of 3J
D Check this box if you are unable to obtain certification from an authorized official, for example. because the organization no longer exists. Provide all requested
information for Items 1. 2. and 3 below. For Item 1, list the organization's address from when you worked there, and consult your W2 records for the EIN. The
Deoartment will re □ uire vou to submit additional evidence of vour □ ualifi.in□ emnlovment. Do not submit sunnortin □ documents until re □ uested to do so.
1. Information about the public service organization at which the borrower is/was employed.
-- REQUIRED --- REQUIRED

Public Service Organization Name Federally Assigned Employer ID# {EIN)
REQUIRED
(a) Dales of employment. Start. - REQUIRED --- End: - REQUIRED (If the borrower Is still employed, put today's date)
Date (MM-DD-YYYY) Dale (MM-DD-YYYY)
(b) Borrower's employment status at your organization: REQUIRED \lilCCk one box and provide lmurS)
D Full-Time Average number of hours per week: ---
D Part-Time Average number of hours per week: ---
For purposes of el1g1b1l1ty

for PSLF, full-time employment Is defined as:
(1) Working In qualifying employment In one or more Jobs for the greater of.
(A) An annual average of at least 30 hours per week or, for a contractual or employment period of at least 8 months. an average of 30 hours per
week, or
(B) Unless the qualifying employment is with two or more employers, the number of hours the employer considers full-time.
(2) Vacation or leave time provided by the employer or leave taken for a condition that is a qualifying reason for leave under the Family and Medical
Leave Act of 1993, 29 U.S.C. 2612(a){1) and (3) is equivalent to hours worked in qualifying employment.
NOTE: A full-time AmeriCorps or Peace Corps volunteer is considered a full-time employee for eligibility purposes for PSLF.
3. Type of Public Service Organization, in accordance with the definition in Section S (check one):
(a) D A government organization {including a Federal, State, local or Tribal organization, agency or entity; a public child or family service agency; or
a Tribal college or university);
(b) □ A non-profit Section 501(c){3) organization;
(o) □ A private, non-profit organization• that provides at least one of the following public services {check all that apply):
□ Emergency management,
□ Military service,
□ Public safety,
□ Law enforcement.
□ Public interest law services,
□ Early childhood education (including licensed or regulated child care. Head Start, and State funded pre-kindergarten),
□ Public service for 1nd1v1dualswith d1sab1l1t1es and the elderly,
□ Public health {1nclud1ngnurses. nurse practitioners, nurses In a clinical setting. and full-time professionals engaged in health care
pract1t1oneroccupations and health support occupations. as such terms are defined by the Bureau of Labor Stat1st1cs),
□ Public education,
□ Public library services,
□ School library services, or
□ Other school-based services.
'A private organization does not qualify 1f11Is {1) a for-profit business, (2) a labor union. or {3) a partisan pol1t1calorganization. Add1t1onally, a
rel1g1ousorganization only qual1f1es1fthe borrower's job duties are unrelated to rel1g1ous1nstruction, worship services, or proselyt1z1ng.
I certify that the borrower ident1f1edIn Seclion 1 above is/was employed at a public service organization, as 1nd1catedabove, or is/was serving In an
AmeriCorps or Peace Corps position (in accordance with the definitions of these terms in Section 5) during the period identified in Item 2{a) of this section.
REQUIRED REQUIRED
Authorized Official's Name {Printed} Authorized Official's Title
REQUIRED (__ )__ REQUIRED REQUIRED
Authorized Official's Siqnature Authorized Official's Teleohone Todav·s Date /mm-dd::;;'"'"\
fedloan·
~ *SERVICING
'
1 U.S. Department of Education
;~ Informll.lion about your feder11I otudent loan
"..,;,...»
P.O Box 69184 Hmnsburg_ PA 17106-9184
Toll-free 855-265-4038 • lnternat1onill 717- 720- 1985
TDD 800-722-8"189 (for hearing impaired milers)
Fax 717-720-1628
www.MyFedLoan org
E',Or?l{O\:\/EI\II_ILLr~.0,rvlE
A.[,Dr?ESSLlr'.E 1
A.[,Dr?ESSLlr'.E 2
PUBLIC SERVICE LOAN FORGIVENESS EMPLOYMENT CERTIFICATION FORM SUBMITTED

ADDITIONAL ACTION REQUIRED
WHY WE ARE CONTACTING YOU
We received the Public Service Loan Forgiveness (PSLF)Employment Certification form (ECF)you recently
submitted. However, we are not able to accept the certification your employer attached with the ECF. In order
to be considered for PSLFyour employer must complete the ECFform. We will consider your previously
submitted ECFclosed.
WHAT ACTIONS YOU NEED TO TAKE

You will need to resubmit a completed ECF if you wish to be considered for participation in the PSLF
Program. Please ensure your employer reads and completes the Certification of Employment Section in
its entirety.
Employer certifications that are not provided as described in the ECFinstructions may result in delayed
processing or denial of your ECF. Common mistakes in the employer certification section include:
- Failure to provide the Employer Identification Number (EIN)
-Failure to certify full or part-time/number of hours
- Misrepresentation under Type of Public Service Organization
- Failure to sign/date or provide title
Please also review the Eligibility Criteria on the reverse of this letter prior to submitting your ECF.
ADDITIONAL INFORMATION YOU MAY FIND HELPFUL

If you have any questions, our PSLFspecialists are here to help. Contact us at the number above or visit
our website MyFedloan.org/PSLF.
WHEN CAN YOU APPLY FOR FORGIVENESS?

Submission of an ECFform allows us to determine whether you meet the criteria for us to begin tracking
your qualifying PSLF employment and payments. You must first make 120 separate, on time, full
monthly payments prior to applying for forgiveness. At that time, a forgiveness application will be
available. No partial forgiveness is available for making less than 120 payments.
WHAT HAPPENS AFTER I MAKE All REQUIRED PAYMENTS AND SUBMIT AN APPLICATION FOR
FORGIVENESS?
You must continue full-time employment with an approved public service organization while making
qualifying payments until the date that your loans are actually forgiven.
CAN I PREPAYMY ACCOUNT?

While you may prepay your account, prepayments generally do not count toward more than one eligible
payment. You should make your normal installment payment each month while you are completing
PSLF requirements.
AM I ENSURED OF OBTAINING FORGIVENESS ONCE I SATISFY ALL PSLF REQUIREMENTS?

In order to benefit from PSLF,most of your qualifying payments must be made under the Income-Based
Repayment (IBR), Pay As You Earn (PAYE), Revised Pay As You Earn (REPAVE),or Income Contingent
Repayment (ICR) Plans. However, you will pay more interest over time under these repayment plans if
you do not ultimately qualify for PSLF.
WHAT ARETHE ELIGIBILITYCRITERIAFOR PARTICIPATIONIN THE PSLFPROGRAM?

You must be employed full-time (in any position) by a public service organization or must be serving in a
full-time AmeriCorps or Peace Corps position at the time you make each qualifying payment.
Organizations that meet the definition of "public service organization" for purposes of the PSLFProgram
are listed below.
• A government organization (including a federal, state, local or tribal organization, agency or
entity; a public child or family service agency; or a Tribal college or university);
• A non-profit, tax-exempt organization* under Section 501(c)(3) of the Internal Revenue Code
(includes most not-for-profit private schools, colleges, and universities);
• A private, non-profit organization* {that is not a labor union or a partisan political organization)
that provides one or more of the following public services:
• Emergency management
• Military service
• Public safety
• Law enforcement
• Public interest law services
• Early childhood education (including licensed or regulated child care, Head Start, and
State-funded prekindergarten)
• Public service for individuals with disabilities and the elderly
• Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-
time professionals engaged in health care practitioner occupations and health support
occupations)
• Public education
• Public library services
• School library service, or other school-based services
*Note: For purposes of the full-time requirement {Section 3, Item 2.(b) of the ECF),your qualifying
employment does not include time spent on job duties that are related to religious instruction, worship
services, or any form of proselytizing.
fedloan·
~ *SERVICING
'
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Fax 717-720-1628
www.MyFedLoan org
E',Or?l{O\:\/EI\II_ILLr~.0,rvlE
A.[,Dr?ESSLlr'.E 1
A.[,Dr?ESSLlr'.E 2

You recently sent us an Employment Certification form (ECF) for employment dates prior to you
consolidating your loans into a Direct Consolidation Loan. Since your loans were not eligible for Public
Service Loan Forgiveness (PSLF)during that time, you need to submit a form that includes employment
certification dates after your Direct Consolidation Loan was disbursed if you want to be considered for
PSLF.

If you are still working for a qualifying employer, complete and return the enclosed ECF. You may
submit this, or any subsequent ECF,at any time.
Please ensure that your employer reads and completes the Certification of Employment (section 3) of
the ECFin its entirety. Employer certifications that are not provided as described in the ECFinstructions
may result in delayed processing or denial of your ECF. Common mistakes in the employer certification
section include:
- Failure to provide the Employer Identification Number (EIN)
-Failure to certify full or part-time/number of hours
- Misrepresentation under Type of Public Service Organization
- Failure to sign/date or provide title


FORGIVENESS?

PSLF requirements.


are listed below.
• Public safety
• Law enforcement
occupations)
fedloan, *SERVICING
5 U.S. Department
:• InformllUon
-·,.,,,_.,;.;f,
aboul
of Education
your foderlll •ludont !olln
PO Box 69'184 Hamsburg, PA 17106-9184
Toil-free 855-265-4038 • International 717-720- 1985
TDD 800-722-8189 (for hearing imprnred milers)
Fax 717-720-1628
WWWMyFedloon.org
DATE
Borrower Name
Address Line 1
Address Line 2
STATUS OF YOUR ELIGIBILITY FOR PUBLIC SERVICE LOAN FORGIVENESS
WHY WE ARE CONTACTINGYOU

We received your Public Service Loan Forgiveness (PSLF)Employment Certification form(s) and
determined that your employer(s) is a qualifying public service organization(s).
Unfortunately, you may not participate in eligibility tracking for the PSLFProgram at this time because
your eligible loans are in default.
WHAT ACTIONSYOU NEEDTO TAKE

If you wish to pursue your eligibility for the PSLFProgram, you must contact your servicer to determine
if there are options available to you to bring your loans out of default.
WHEN CAN YOU APPLYFOR FORGIVENESS?

You may apply for loan forgiveness after you have made 120 on-time qualifying payments. You must be
working for a qualifying public service organization at the time you submit the application for
forgiveness and at the time the remaining balance on your loan is forgiven. A final determination of
your eligibility for forgiveness will occur upon receipt of your application.
While applying for and receiving forgiveness, you must continue full-time employment with a qualifying
public service organization while making on-time qualifying payments under one of the approved
repayment plans until you have received notice that you may cease making payments on your Direct
Loan(s).
THINGS TO REMEMBER
Although we will maintain copies of any documents that we receive, we recommend that you keep
OBTAINED BY STUDENT
copies ofBORROWER PROTECTION
all forms that CENTER
you submit and AND
any AMERICAN
supportingFEDERATION OF TEACHERS
documentation UNDER
regarding yourTHE FREEDOM OF
employment INFORMATION ACT
and
the PSLFProgram. We also recommend that you submit an employment certification annually so that
we can update you on your progress toward your forgiveness eligibility date. The Employment
Certification Form and additional information regarding the program can be found on our website at
www .MyFed Loan.org/PSLF.
Note: in order to have any remaining loan balance to forgive under the PSLFProgram, most of your
payments must be made under the Income-Based Repayment (IBR), Pay As You Earn(PAYE),Revised Pay
As You Earn (REPAVE), or Income Contingent Repayment (ICR) Plans. However, you will pay more
interest over time under these repayment plans if you are not ultimately eligible for loan forgiveness
under PSLF.
Prepayments generally will not count toward more than one qualifying payment and no partial
forgiveness is available for making less than 120 payments.
ADDITIONAL QUESTIONSREGARDINGTHE CURRENTSTATUSOF YOUR LOANS?

If you have any questions regarding the current status of your loan(s), please contact your current
servicer for additional information.
fedloan·
~-• SERVICING
'1 U.S. Department
"..,;,...»
;~ Informll.lion
of Education
about your feder11I otudent loan
Fax 717-720-1628
www.MyFedLoan org
DATE
BORROWERNAME
ADDRESSLINE 1
ADDRESSLINE 2
ADRESSSLINE 3
STATUS OF YOUR ELIGIBILITY FOR PUBLIC SERVICE LOAN FORGIVENESS

We received the Public Service Loan Forgiveness (PSLF) Employment Certification Form (ECF) you
recently submitted. Unfortunately, we are unable to process your request because the ECF you
submitted is not an Office of Management and Budget (0MB) approved form.

You will need to resubmit your employment information on an 0MB approved ECF{provided with this
letter) if you wish to be considered for participation in the PSLF Program. Please ensure the ECF is
completed in its entirety and is properly signed by you and your employer.
Sections of the form that are not completed in strict accordance with the ECFinstructions may result in
delayed processing or denial of your ECF. Common mistakes in the employment information and
employer certification sections include:
Failure to provide the Employer Identification Number (EIN)
Failure to certify full or part-time status and number of hours per week
Misrepresentation of the type of organization which employs you
Failure to sign, date or provide title of Authorized Official
Failure to check the box in Section 4 that certifies all information in Section 3 is true, complete,
and correct

our website MyFedLoan.org/PSLF.

CAN I PREPAY MY ACCOUNT?

PSLFrequirements.
AM I ENSURED OF OBTAINING FORGIVENESS ONCE I SATISFY All PSLF REQUIREMENTS?

Repayment (IBR), Pay As You Earn (PAYE),Revised Pay As You Earn (REPAVE),or Income Contingent
WHAT ARE THE ELIGIBILITY CRITERIA FOR PARTICIPATION IN THE PSLF PROGRAM?
are listed below.
• Public safety
• Law enforcement
occupations)
fedloan·
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Fax 717-720-1628
www.MyFedLoan org
H(lk~'.(l'/VI ~'.~lJI I r,Ji\rvll

1\DUR[SS Llf\[ 1
1\DUR[SS Llf\[ 2

We received the Public Service Loan Forgiveness (PSLF) Employment Certification form (ECF) you
recently submitted. In Section 4: Employer Certification, your employer did not check the box certifying
that the information in Section 3 is true, complete, and correct. We will consider your previously
submitted ECF closed.
What actions you need to take - You will need to resubmit a completed ECF if you wish to be
considered for participation in PSLF tracking. Please ensure your employer reads and completes the
Employment Information & Employer Certification Sections in their entirety.
Sections of the form that are not completed in strict accordance with the ECF instructions may result in
Failure to provide the EIN (Employer Identification Number)
Failure to sign, date or provide title
If you have any questions, our trained PSLF specialists are here to help. Contact us or visit
MyFedloan .org/PSLF.
When Can I Apply for Forgiveness?

Submission of an ECF form allows us to determine whether you meet the criteria for us to begin tracking
What Happens After I Make All Required Payments and Submit an Application for Forgiveness?
Can I Prepay My Account?
payment. You should make your normal installment payment each month while you are completing PSLF
requirements.
What Are the Eligibility Criteria for Participating in the PSLF program?
Organizations that meet the definition of "public service organization" for purposes of the PSLF Program
are listed below.
• A non-profit, tax-exempt organization• under Section 501 (c)(3) of the Internal Revenue Code
• A private, non-profit organization* (that is not a labor union or a partisan political organization)
• Public safety
• Law enforcement
• Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-time
professionals engaged in health care practitioner occupations and health support
occupations)
*Note: For purposes of your average number of hours per week (Section 8 of the ECF), do not include
hours spent on religious instruction, worship services, or proselytizing.
fedloan·
~ *SERVICING
'
"..,;,...»
Fax 717-720-1628
www.MyFedLoan org
DATE
BORROWERNAME
ADDRESSLINE 1
ADDRESSLINE 2
ADRESSSLINE 3


We received the Public Service Loan Forgiveness (PSLF)Employment Certification form (ECF)you recently submitted.
However, the U.S. Department of Education has modified the eligibility criteria described in the ECF. Therefore, we need
you to resubmit your employment information on an updated ECFto be considered. We will consider your previously
submitted ECFto be closed.
We apologize for any inconvenience this may cause.

Complete and submit the revised ECFprovided with this letter. You may submit this, or any subsequent ECF,at any time.
Please ensure that your employer reads and completes the Certification of Employment Section of the ECFin its entirety.
Employer certifications that are not provided in strict accordance with the ECFinstructions may result in delayed
Failure to certify full or part-time/number of hours
Misrepresentation under Type of Public Service Organization
Failure to sign/date or provide title

If you have any questions, our trained PSLFspecialists are here to help. Contact us at the number above or visit our
website MyFedloan.org/PSLF.
Submission of an ECFform allows us to determine whether you meet the criteria for us to begin tracking your qualifying
PSLFemployment and payments. You must first make 120 separate, on time, full monthly payments prior to applying for
forgiveness. At that time, a forgiveness application will be available. No partial forgiveness is available for making less
than 120 payments.
WHAT HAPPENS AFTER I MAKE ALL REQUIRED PAYMENTS AND SUBMIT AN APPLICATION FOR FORGIVENESS?
You must continue full-time employment with an approved public service organization while making qualifying payments
until the date that your loan(s) are actually forgiven.

While you may prepay your account, prepayments generally do not count toward more than one eligible payment. You
should make your normal installment payment each month while you are completing PSLFrequirements.
AM I ENSUREDOF OBTAINING FORGIVENESSONCE I SATISFYALL PSLFREQUIREMENTS?

In order to benefit from PSLF,most of your qualifying payments must be made under the Income-Based Repayment (IBR),
Pay As You Earn (PAYE),Revised Pay As You Earn (REPAVE),or Income Contingent Repayment (ICR) Plans. However, you
will pay more interest over time under these repayment plans if you do not ultimately qualify for PSLF.
You must be employed full-time (in any position) by a public service organization or must be serving in a full-time
AmeriCorps or Peace Corps position at the time you make each qualifying payment. Organizations that meet the
definition of "public service organization" for purposes of the PSLFProgram are listed below.
• A government organization (including a federal, state, local or tribal organization, agency or entity; a
public child or family service agency; or a Tribal college or university);
•Anon-profit, tax-exempt organization* under Section S01(c)(3) ofthe Internal Revenue Code (includes
most not-for-profit private schools, colleges, and universities);
• A private, non-profit organization* (that is not a labor union or a partisan political organization) that
provides one or more of the following public services:
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated child care, Head Start, and State-
funded prekindergarten)
professionals engaged in health care practitioner occupations and health support occupations)
*Note: For purposes of the full-time requirement (Section 3, Item 2.(b) of the ECF),your qualifying employment
does not include time spent on job duties that are related to religious instruction, worship services, or any form
of proselytizing.
fedloan,
~-•SERVICING
"''
~--?i'~
U.S. Department of Education
:ij{/
.,,,,,~,,..:
Inform,U.lon aboul your feder11l 5tudent loan
P.O. Box 69184 Harrisburg, PA 17106-9184
Toil-free 855-265-4038 • International 717-720-1985
TDD 800-722-8189 (for he<mng impaired rnllers)
Fax 717-720-1628
www MyFedloan org
MONTH DAY, YEAR
First Name Last Name

ADDRESS1
ADDRESS2
ADRESSS3
RESPONSE TO THE EMPLOYMENT CERTIFICATION FORM YOU SUBMITTED FOR THE PUBLIC
SERVICE LOAN FORGIVENESS PROGRAM

We reviewed the Public Service Loan Forgiveness (PSLF) Employment Certification form(s) you
submitted and determined that you may not participate in employment and payment tracking for the PSLF
program at this time or that additional information is needed to complete our review of your Employment
Certification form. See below for further information and action you may need to take.
NOT ELIGIBLE: No Evidence Showing Employment at Public Service Organization Listed on the
Employment Certification Form.

If your eligibility status is:
MISSING INFORMATION If you would like us to reconsider the Employment
Certification form. please resubmit the form with all
required fields completed Your loans will remain with
your current servicer(s) until a valid ECF is submitted.
NOTE: Missing information could indicate that the
field 'Nas left blank: the information provided 1.,:as
illegible or v:as not exactly ·:;hat was requested: or the
information was altered and the initials of the amender
':1ere not present.
NOT ELIGIBLE If you can provide additional evidence or information
that you believe qualifies your employment. please
resubmit the Employment Certification Form with the
additional information For your reference. we have
included the qualifying loan repayment and
employment criteria for the PSLF Program
UNDER REVIEW We are unable to determine if your employer is a
qualifying public service organization and need to
conduct a more thorough revie'.v. Once our review is
complete. we will provide you v:ith additional details
regarding your employment eligibility for the PSLF
program.

You may apply for loan forgiveness after you have made 120 on-time qualifying payments. You must be
working for a qualifying public service organization at the time you submit the application for forgiveness
and at the time the remaining balance on your loan is forgiven. A final determination of your eligibility for
forgiveness will occur upon receipt of your application.
While applying for and receiving forgiveness, you must continue full-time employment with a qualifying
public service organization while making on-time qualifying payments under one of the approved
repayment plans until you have received notice that you may cease making payments on your Direct
Loan(s).
THINGS TO REMEMBER
Although we will maintain copies of any documents that we receive, we recommend that you keep copies
of all forms that you submit and any supporting documentation regarding your employment and the PSLF
Program. We also recommend that you submit an employment certification annually so that we can
update you on your progress toward your forgiveness eligibility date. The Employment Certification Form
and additional information regarding the program can be found on our website at
www.MyFedLoan.org/PSLF.
Note: In order to have any remaining loan balance to forgive under the PSLF Program, most of your
payments must be made under the Income-Based Repayment (IBR), Pay As You Earn, or Income
Contingent Repayment (ICR) Plans. However, you will pay more interest over time under these
repayment plans if you are not ultimately eligible for loan forgiveness under PSLF.
Prepayments generally will not count toward more than one qualifying payment and no partial forgiveness
is available for making less than 120 payments.

If you have any questions or need additional assistance, our trained loan specialists are here to help. You
may contact us at the number listed on the front of this letter.
LOAN REPAYMENT AND EMPLOYMENT CRITERIA FOR PARTICIPATION IN THE PSLF PROGRAM
You must have made 120 on-time, separate, monthly payments after October 1, 2007, on the Direct Loan
Program loans for which forgiveness is requested. Payments made prior to October 2, 2007 do not count
toward meeting this requirement. Each of the 120 monthly payments must be made for the full, scheduled
installment amount within 15 days of the due date.
The 120 required payments must be made under one or more of the following Direct Loan Program
repayment plans:
• Income-Based Repayment (IBR) Plan (not available for parent Direct PLUS Loans or Direct
Consolidation Loans that repaid a parent PLUS Loan)
• Income Contingent Repayment (ICR) Plan (not available for parent Direct PLUS Loans or Direct
PLUS Consolidation Loans)
• Standard Repayment Plan with a 10-year repayment period
• Any other Direct Loan Program repayment plan; but only payments that are at least equal to the
monthly payment amount that would have been required under the Standard Repayment Plan
with a 10-year repayment period may be counted toward the required 120 payments.
You must be employed full-time (in any position) by a public service organization, or must be serving in a
Organizations that meet the definition of "public service organization" for purposes of the PSLF Program
are listed below.
• A government organization (including a federal, state, local or tribal organization, agency, or

entity; a public child or family service agency; or a tribal college or university);
• A non-profit, tax-exempt organization under Section 501 (c)(3) of the Internal Revenue Code
• A private, non-profit organization (that is not a labor union or a partisan political organization) that
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated health care, Head Start, and
state-funded prekindergarten)
time professionals engaged in health care practitioner occupations and health care
support occupations)
• School library or other school-based services
*A private organization does not qualify if it is (1) a for-profit business, (2) a labor union, or (3) a partisan
political organization. Additionally, time spent participating in religious instruction, worship services, or any
form of proselytizing may not be included when determining full-time public service employment.
fedloan"
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS PO
~ kSERVICING
UNDER BoxTHE
69184 Harrisburg
FREEDOM OF PA 17·1 □ 6-9·184
INFORMATION ACT
Toll-free 855-265-4038 • International 717-720-1985
TDD 800-722-8'189 (for hearing imprnred rnllers)
Fnx 717-720-1628
www MyFedloan org
CORP,0\:\/[R FULL ~J;\f·vl[

1\DUR[SS Llf\[ 1
1\DUR[SS Llf\[ 2


recently submitted. We are not able to accept your signature in Section 2 and your employer's
signature in Section 4: Employer Certification. In order for us to accept your ECF,you and your employer
must physically sign the ECF (wet signature) or provide a digital facsimile signature (digitally drawn
signature). For this reason, we have denied the ECFand will consider it closed.

You will need to resubmit a completed ECFif you wish to be considered for participation in employment
and payment tracking for the PSLFProgram. Please ensure the ECF is completed in its entirety and is
properly signed by you and your employer.
and correct



PSLFrequirements.

are listed below.
• Public safety
• Law enforcement
occupations)
fedloan·
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS
*SERVICING
~~'5
~~:
~··-·~·•';.,;
U.S. Department
lnror,nallun
UNDER THE
PO Box69·184 FREEDOM
Harrisburg_
of Education
PA OF INFORMATION ACT
17106-9184
about yuur 1.. <1eral olud .. ni loan

Toil-free 855-265-4038 • International 717-720-1985
TDD 800-722-8·1sr1{for hearing impaired milers)
Fax 717-720-1628
www MyFedlmrn org
t',ORFiO\."\'ERil_lLL r,J.Li,rvlE
A[XlRE)) Lin l
A[XlRE)) Lin 2


recently submitted. We are not able to accept your signature in Section 2. In order for us to accept your
ECF, you must physically sign the ECF (wet signature) or provide a digital facsimile signature (digitally
drawn signature). For this reason, we have denied the ECFand will consider it closed.

and correct



PSLFrequirements.

are listed below.
• Public safety
• Law enforcement
occupations)
fedloan-
~·SERVICING
P.O. Box 68184 Hmr1sburg PA 17I06-'.H84
I oll tree 8~~ 2b~ 40:18 • International r I/ /20 1~8~
TDD 800-777-818~ (for l1em,ng ,mpmred milers)
FJX 717-720-1628
www.MyFedLoon org

1\DUR[SS Llf\[ 1
1\DUR[SS Llf\[ 2


recently submitted. We are not able to accept your employer's signature in Section 4: Employer
Certification. In order for us to accept your ECF, your employer must physically sign the ECF (wet
signature) or provide a digital facsimile signature (digitally drawn signature). For this reason, we have
denied the ECFand will consider it closed.

and correct


PSLFrequirements.

are listed below.
• Public safety
• Law enforcement
occupations)
f loan· ~
SERVICING
U.S. Department
~ lnformaUon
of Education
aboul your fedoro.l atudcnt loan
RESPONSE TO THE
EMPLOYMENT CERTIFICATION
FORM YOU SUBMITTED FOR
THE PUBLIC SERVICE LOAN
December 30, 2016 FORGIVENESS PROGRAM
Account Number:
Why We are Contacting You

We received the Public Service Loan Forgiveness (PSLF) Employment Certification Forms you submitted and determined
that the employers listed below are qualifying employers for the purpose of PSLF.
Employer Name I Qualifying Employment Begin Date I Qualifying Employment End Date I
Your employment qualifies you for participation in the PSLF Program for the certified employment time periods provided
above. Note: If the dates of employment that you submitted on the form differ from those listed above, it may be due to
overlapping employment periods, dates certified into the future, or periods of employment on or before October 1, 2007
(which do not qualify for PSLF).
It you have any U.S. Department of Education owned student loans that are not already serviced by FedLoan Servicing, we
will contact your current servicers to request a transfer of all of your loans to us. This transfer will allow you to manage all of
your loans in one location and closely track your progression toward PSLF. Please allow a few weeks for the entire transfer
process to be completed.
Qualifying Payment Tracking for Public Service Loan Forgiveness

In the next few weeks, we will calculate and provide you with notification of:
• The number of qualifying payments you have made during the qualifying employment period listed above,
• The total number of qualifying payments you have made during all periods of qualifying employment approved to
date,
• The estimated number of payments that are still required, and
• The date you are expected to be eligible to apply for forgiveness .
After we calculate the number of qualifying payments you have made, keeping track of your progression toward PSLF is
easy.
• Log in to Account Access at MyFedLoan.org
0
P.O. Box 69184. Harrisburg. PA 17106-91841 M-F 8AM to 9PM (ET) I (855-265-40381 International 717-720-19851 ·l::':1::·
711
MyFedLoan.org
• Check your monthly bill
• Review the communication that we send you each time you submit a new Employment Certification Form (ECF)
We will update your qualifying payment count each time you submit a new, approved ECF if you made additional qualifying
payments during the new certified employment period. We recommend that you submit an ECF annually. When it is time to
certify your employment, you can log in to MyFedloan.org to get started.
When can you apply for forgiveness? You may apply for loan forgiveness after you have made 120 on-time qualifying
payments. You must be working for a qualifying employer at the time you submit the application for forgiveness and at
the time the remaining balance on your loan is forgiven. We will provide you with a final determination of your eligibility for
forgiveness after we receive your application.
Although we will maintain copies of any documents that we receive, we recommend that you keep copies of all forms that
you submit and any supporting documentation regarding your employment and the PSLF Program.
What is a qualifying payment? A qualifying payment for PSLF is a payment that is made:
• Each month, satisfying your monthly payment amount

• On time (received no later than 15 days after the payment due date)
• Under one of the eligible repayment plans for PSLF
• While you are employed full-time at a qualifying employer
What is a qualifying repayment plan? In order to receive forgiveness under the PSLF Program, you must make most of
your payments under one of the following plans:
• Pay As You Earn (PAYE)

• Revised Pay As You Earn (REPAVE)
• Income-Based Repayment (IBR)
• Income-Contingent Repayment (ICR)
Prepayments generally will not count toward more than one qualifying payment and no partial forgiveness is available for
making less than 120 qualifying payments.
Questions? If you have any questions regarding the Public Service Loan Forgiveness Program, we have loan specialists
that are here to help. Contact us by any of the methods provided.
fedloan-
~-•SERVICING
JULY29,2016
•
~
'"
5 U.S. Department
: Inlorma.tlon
'
,,,~,~,~
of Education
a.bout your fe<leral student loe.n
P.O. Box 69184 Harrisburg, PA 17106-9184
Toll-free 855-265-4038 • lnt'I 717- 720-1985
Fax717-720-1628"TTY:
Monday-Friday 8am to 9pm ET
www.MyFedLoan.org
Dial711
RESPONSE TO THE EMPLOYMENT CERTIFICATION FORM YOU SUBMITTED FOR THE

PUBLIC SERVICE LOAN FORGIVENESS PROGRAM
Why We are Contacting You

We received the Public Service Loan Forgiveness (PSLF) Employment Certification Form you submitted and
determined that the employers listed below are qualifying employers for the purpose of PSLF.
EMPLOYER BEGIN DATE END DATE

NAME CERTIFIED CERTIFIED
Your employment qualifies you for participation in the PSLF Program for the certified employment time periods
provided above. Note: If the dates of employment that you submitted on the form differ from those listed above, it may
be due to overlapping employment periods, dates certified into the future, or periods of employment on or before
October 1, 2007 (which do not qualify for PSLF).
What Happens Next

We will contact your current servicers to request a transfer of all of your U.S. Department of Education owned loans to
us. This transfer will allow you to manage all of your loans in one location and closely track your progression toward
PSLF. Please allow a few weeks for the entire transfer process to be completed.
Qualifying Payment Tracking for Public Service Loan Forgiveness

Once your servicer transfers your loans to us, we will calculate and provide you with notification of:
• The number of qualifying payments you have made during the qualifying employment period listed above,
• The total number of qualifying payments you have made during all periods of qualifying employment approved to
date,
• The estimated number of payments that are still required, and
• The date you are expected to be eligible to apply for forgiveness.
After we receive your loans and calculate the number of qualifying payments you have made, keeping track of your
progression toward PSLF is easy.
Log in to Account Access at MyFedloan.org
Check your monthly bill
Review the communication that we send you each time you submit a new ECF
We will update your qualifying payment count each time you submit a new, approved ECF it you made additional
qualifying payments during the new certified employment period. We recommend that you submit an ECF annually.
When it is time to certify your employment, you can log in to MyFedLoan.org to get started.
When can you apply for forgiveness?

You may apply for loan forgiveness after you have made 120 on-time qualifying payments. You must be working for
a qualifying employer at the time you submit the application for forgiveness and at the time the remaining balance on
your loan is forgiven. We will provide you with a final determination of your eligibility for forgiveness after we receive
your application.
Although we will maintain copies of any documents that we receive, we recommend that you keep copies of all forms
that you submit and any supporting documentation regarding your employment and the PSLF Program.
What is a qualifying payment? A qualifying payment for PSLF is a payment that is made:
• Each month, satisfying your monthly payment amount
• On time (received no later than 15 days after the payment due date)
• Under one of the eligible repayment plans for PSLF
• While you are employed full-time at a qualifying employer
What is a qualifying repayment plan? In order to receive forgiveness under the PSLF Program, you must make
most of your payments under one of the following plans:
Pay As You Earn (PAYE)

Revised Pay As You Earn (REPAVE)
Income- Based Repayment (IBR)
Income- Contingent Repayment (ICR)
Prepayments generally will not count toward more than one qualifying payment and no partial forgiveness is available
for making less than 120 qualifying payments.
Important Information
Continue to make payments to your current servicers until you are notified that the loans have transferred to us. In
order for a payment to qualify tor Public Service Loan Forgiveness, it must be made on-time (received no later than 15
days after the payment due date) so it is important to continue to make your scheduled monthly payment.
If for any reason we receive additional information from your current servicers indicating that your loans are not able to
be transferred at this time, we will notify you.
Questions?
If you have any questions regarding the Public Service Loan Forgiveness Program, we have loan specialists that are
here to help. Contact us by any of the methods provided.
SERVICING
January 4, 2016
•
~
-
. "
.,,,,_,,,.
\ U.S. Department of Education
-~ lnformallon a!Joul your federal student loan
WE COULD NOT
ACCEPT YOUR PUBLIC
SERVICE EMPLOYMENT
CERTIFICATION.
Account Number:
We reviewed the Public Service Loan Forgiveness (PSLF) Employment Certification Forms you submitted and determined
that you may not participate in employment and payment tracking for PSLF or that we need additional information to
complete our review.
MISSING INFORMATION: Your Social Security Number

MISSING INFORMATION: Your Full Name
MISSING INFORMATION: Your Date of Birth
MISSING INFORMATION: Your Signature
MISSING INFORMATION: Date You Signed Form
MISSING INFORMATION: Employer Name
MISSING INFORMATION: Valid Employer ID Number (EIN)
MISSING INFORMATION: Employer Mailing Address
MISSING INFORMATION: Employment Begin Date
MISSING INFORMATION: Employment End Date
MISSING INFORMATION: Employment Begin/End Dates Not Valid
MISSING INFORMATION: Employment Status
MISSING INFORMATION: Average Hours Per Week
MISSING INFORMATION: Public Service Organization Type
MISSING INFORMATION: Non-Profit Organization Type
MISSING INFORMATION: Authorized Official's Name
MISSING INFORMATION: Authorized Official's Title
MISSING INFORMATION: Authorized Official's Signature
MISSING INFORMATION: Authorized Official's Telephone
MISSING INFORMATION: Date Authorized Official Signed Form
MISSING INFORMATION: Official Not Eligible to Certify
NOT ELIGIBLE: Organization Does Not Qualify
NOT ELIGIBLE: No Eligible Loan Types
UNDER REVIEW: Your eligibility for PSLF is being reviewed
What Actions You Need to Take

Depending on your eligibility status (listed above), you may still be able to participate in PSLF tracking with us. Identify your
situation below to determine what actions you can take.
If your eligibility status is MISSING INFORMATION ...Submit or re-submit an Employment Certification Form with all
required fields completed.
P.O. Box 69184, Harrisburg, PA 17106-91841 M-F 8AM to 9PM (ET} I ( 855-265-40381 International 717-720-19851 ~ 717-720-16281 ~ 711
MyFedLoan.org
Privacy Notice: Federal law requires us to tell you how we collect. share, and protect your personal ,nformat,on
Our privacy policy has not changed and can be viewed anytime at MyFedloan.orglPrivacyPol1cy. We will mail you a copy if you contact us.
We use this status if a field was left blank, the information was illegible, or was not exactly what was requested. You also
may see this status if you or your employer made any changes to an existing application, wrote-in information on the
margins, or crossed out information and did not initial each change.
We attached a new form for you to complete and return. Please make sure your new Employment Certification Form is
complete, clear, and initialed where necessary. Your loans will remain with your current servicer until you submit a valid
Employment Certification Form.
If your eligibility status is ORGANIZATION DOES NOT QUALIFY ... Based on what you submitted, your employer does
not appear to qualify for PSLF. We included a list of eligibility requirements for PSLF employment below, in the section titled
EMPLOYMENT ELIGIBILITY.
Please review the employment requirements and reapply if you can provide additional information to show that your
employment qualifies.
If your eligibility status is NO ELIGIBLE LOAN TYPES ... PSLF is only available for loans made under the William D. Ford
Federal Direct Loan Program (Direct Loans). However, loans made under other federal programs may qualify for PSLF if
you consolidate them into a Direct Consolidation Loan and repay them on an eligible repayment plan.
For more information about Direct Loan Consolidation, including eligibility requirements, visit StudentLoans.gov. If you
choose to consolidate, you will need to complete a new Employment Certification Form that includes a period of qualifying
employment after the Direct Consolidation Loan is disbursed. Only payments made during periods of qualifying employment
on the Direct Consolidation Loan will count toward the required 120 monthly payments as your existing loans are not eligible
for PSLF.
Also keep in mind that we did not evaluate your employment because your loans are not eligible for PSLF. It is possible
that, in addition to your loan ineligibility, your employment may not qualify for PSLF.
Before you consolidate, please review the EMPLOYMENT ELIGIBILITY below to see what types of employers qualify.
Generally, employment will not qualify if you work for a publicly-traded company, a for-profit company, or a company that
does not perform any qualifying public service.
If your eligibility status is UNDER REVIEW ... Based on the information provided, we couldn't determine if your
employment qualifies for PSLF or if you meet all requirements for PSLF. We are reviewing your account and will contact you
when we determine your eligibility to participate in PSLF tracking.
When can you apply for forgiveness? You may apply for loan forgiveness after you make 120 on-time, qualifying
payments (at least 10 years). While applying for and receiving forgiveness, you must continue full-time employment with a
qualifying public service organization while making on-time qualifying payments under one of the approved repayment plans
until you have received notice that you may cease making payments on your Direct Loans. A final determination of your
eligibility for forgiveness will occur when we receive your application.
Good to Know
• Although we maintain copies of any documents we receive, we recommend that you keep copies of all forms that
you submit and any supporting documentation regarding your employment and PSLF.
• We recommend that you submit employment certification annually so that we can update you on your progress
toward forgiveness, including the date we expect you to be eligible to apply for PSLF
• In order to have any remaining loan balance to forgive through PSLF, most of your payments must be made under
an Income-Driven Repayment plan. However, you will pay more interest over time under these repayment plans if
you are not ultimately eligible for loan forgiveness under PSLF.
• Prepayments generally will not count toward more than one qualifying payment and no partial forgiveness is
available for making less than 120 payments.
Visit MyFedloan.org/PSLF for the Employment Certification Form and more information on the program, or contact our
PSLF specialists at the number provided.
Eligibility Criteria for Participation in the Public Service Loan Forgiveness Program
Participant Eligibility
You must have made 120 on-time, separate, monthly payments after October 1, 2007, on the Direct Loan Program loans
for which forgiveness is requested. Payments made prior to October 2, 2007 do not count toward meeting this requirement.
Each of the 120 monthly payments must be made for the full, scheduled installment amount within 15 days of the due date.
The 120 required payments must be made under one or more of the following Direct Loan Program repayment plans:
• Pay As You Earn (PAYE) Repayment plan (not available for parent Direct PLUS Loans or Direct Consolidation
Loans that repaid a parent PLUS Loan)
• Revised Pay As You Earn (REPAVE) plan (not available for parent Direct PLUS Loans or Direct Consolidation
Loans that repaid a parent PLUS Loan) NOTE: If you do not recertify on time annually you will be placed on an
alternative repayment plan. The payments made while on the alternative repayment plan are not PSLF eligible.
• Income-Based Repayment (IBR) plan (not available for parent Direct PLUS Loans or Direct Consolidation Loans
that repaid a parent PLUS Loan)
• Income-Contingent Repayment (ICR) plan (not available for parent Direct PLUS Loans or Direct PLUS
Consolidation Loans)
• Standard Repayment plan with a 10-year repayment period
• Any other Direct Loan Program repayment plan; but only payments that are at least equal to the monthly payment
amount that would have been required under the Standard Repayment Plan with a 10-year repayment period may
be counted toward the required 120 payments.
You must be employed full-time (in any position) by a public service organization, or must be serving in a full-time
AmeriCorps or Peace Corps position at the time you make each qualifying payment. Organizations that meet the definition
of "public service organization" for purposes of the PSLF Program are listed below.
• A government organization (including a federal, state, local or tribal organization, agency, or entity; a public child or
family service agency; or a Tribal college or university);
• A non-profit, tax-exempt organization* under Section 501 (c)(3) of the Internal Revenue Code (includes most not-for-
profit private schools, colleges, and universities);
• A private, non-profit organization* (that is not a labor union or a partisan political organization) that provides one or
more of the following public services:
0 Emergency management
o Military service
o Public safety
o Law enforcement
0 Public interest law services
0 Early childhood education (including licensed or regulated child care, Head Start, and State-funded pre-
kindergarten)
c, Public service for individuals with disabilities
0 Public service for the elderly
c, Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-time professionals
engaged in health care practitioner occupations and health support occupations)
c, Public education
0 Public library services
0 School library services, or other school-based services
*Note: For purposes of the full-time requirement (Section 3, Item 7 of the ECF), your qualifying employment does not
include time spent on job duties that are related to religious instruction, worship services, or any form of proselytizing.
Click the following link to access your form: Employment Certification Form
fedloan-
~-·SERVICING
U.S. Department
Inlorme.t!on
of Education
a.bout your red•m•l student lolln
P.O. Box69184 Harrisburg. PA 17106-9184
Toll-tree 855-265-4038 • lnt'I 717-720-1985
Fax 717-720-1628 "TTY: Oial711
Monday-Friday Sam to 9pm ET
www.MyFedLoan.org
DECEMBER 31, 2016
WE COULD NOT ACCEPT YOUR PUBLIC SERVICE EMPLOYMENT CERTIFICATION
We reviewed the Public Service Loan Forgiveness (PSLF) Employment Certification Forms you submitted and
determined that you may not participate in employment and payment tracking for the PSLF Program or that we need
additional information to complete our review.
MISSING INFORMATION: Your Social Security Number

MISSING INFORMATION: Your Full Name
MISSING INFORMATION: Your Date of Birth
MISSING INFORMATION: Your Signature
MISSING INFORMATION: Date You Signed Form
MISSING INFORMATION: Employer Name
MISSING INFORMATION: Valid Employer ID Number (EIN)
MISSING INFORMATION: Employer Mailing Address
MISSING INFORMATION: Employment Begin Date
MISSING INFORMATION: Employment End Date
MISSING INFORMATION: Employment Begin/End Dates Not Valid
MISSING INFORMATION: Employment Status
MISSING INFORMATION: Average Hours Per Week
MISSING INFORMATION: Public Service Organization Type
MISSING INFORMATION: Non-Profit Organization Type
MISSING INFORMATION: Authorized Official's Name
MISSING INFORMATION: Authorized Official's Title
MISSING INFORMATION: Authorized Official's Signature
MISSING INFORMATION: Authorized Official's Telephone
MISSING INFORMATION: Date Authorized Official Signed Form
MISSING INFORMATION: Official Not Eligible to Certify
NOT ELIGIBLE: No Eligible Loan Types
UNDER REVIEW: Your eligibility for PSLF is being reviewed

Depending on your eligibility status (listed above), you may still be able to participate in PSLF tracking with us. Identify
your situation below to determine what actions you can take.
If your eligibility status is MISSING INFORMATION ...
Submit or re-submit an Employment Certification form with all required fields completed.
We use this status if a field was left blank, the information was illegible, or was not exactly what was requested. You
also may see this status if you or your employer made any changes to an existing application, wrote-in information
on the margins, or crossed out information and did not initial each change.
We attached a new form for you to complete and return. Please make sure your new Employment Certification form
is complete, clear, and initialed where necessary. Your loans will remain with your current servicer until you submit
a valid Employment Certification Form.
If your eligibility status is ORGANIZATION DOES NOT QUALIFY ...
Based on what you submitted, your employer does not appear to qualify for PSLF. We included a list of eligibility
requirements for PSLF employment below, in the section titled EMPLOYMENT ELIGIBILITY. Please review the
employment requirements and reapply if you can provide additional information to show that your employment
qualifies.
If your eligibility status is NO ELIGIBLE LOAN TYPES ...
PSLF is only available for loans made under the William D. Ford Federal Direct Loan Program (Direct Loans).
However, loans made under other federal programs may qualify for PSLF if you consolidate them into a Direct
ConsolidationLoanand repaythem on an eligiblerepaymentplan.
For more information about Direct Loan Consolidation, including eligibility requirements, visit StudentLoans.gov. If
you choose to consolidate, you will need to complete a new Employment Certification form that includes a period of
qualifying employment after the Direct Consolidation Loan is disbursed. Only payments made during periods of
qualifying employment on the Direct Consolidation Loan will count toward the required 120 monthly payments as
your existing loans are not eligible for PSLF.
Also keep in mind that we did not evaluate your employment because your loans are not eligible for PSLF. It is
possible that, in addition to your loan ineligibility, your employment may not qualify for PSLF.
Before you consolidate, please review the EMPLOYMENT ELIGIBILITY below to see what types of employers qualify.
Generally, employment will not qualify if you work for a publicly-traded company, a for-profit company, or a company
that does not perform any qualifying public service.
If your eligibility status is UNDER REVIEW ...
Based on the information provided, we couldn't determine if your employment qualifies for PSLF or if you meet all
requirements for PSLF. We are reviewing your account and will contact you when we determine your eligibility to
participate in PSLF tracking.
When can you apply for forgiveness?
You may apply for loan forgiveness after you make 120 on-time, qualifying payments (at least 10 years). While
applying for and receiving forgiveness, you must continue full-time employment with a qualifying public service
organization while making on-time qualifying payments under one of the approved repayment plans until you have
received notice that you may cease making payments on your Direct Loans. A final determination of your eligibility for
forgiveness will occur when we receive your application.
Good to Know
Although we maintain copies of any documents we receive, we recommend that you keep copies of all forms that
you submit and any supporting documentation regarding your employment and PSLF.
We recommend that you submit employment certification annually so that we can update you on your progress
toward forgiveness, including the date we expect you to be eligible to apply for PSLF.
In order to have any remaining loan balance to forgive through PSLF, most of your payments must be made under
an Income-Driven Repayment plan. However, you will pay more interest over time under these repayment plans if
you are not ultimately eligible for loan forgiveness under PSLF.
Prepayments generally will not count toward more than one qualifying payment and no partial forgiveness is
available for making less than 120 payments.
Visit MyFedloan.org/PSLF for the Employment Certification form and more information on the program, or contact our
PSLF specialists at the number provided.
ELIGIBILITY CRITERIA FOR PARTICIPATION IN THE PUBLIC SERVICE LOAN FORGIVENESS PROGRAM
You must have made 120 on-time, separate, monthly payments after October 1, 2007, on the Direct Loan Program
loans for which forgiveness is requested. Payments made prior to October 2, 2007 do not count toward meeting this
requirement. Each of the 120 monthly payments must be made for the full, scheduled installment amount within 15
days of the due date.
Pay As You Earn (PAYE) Repayment plan (not available for parent Direct PLUS Loans or Direct
Revised Pay As You Earn (REPAVE) plan (not available for parent Direct PLUS Loans or Direct
Consolidation Loans that repaid a parent PLUS Loan) NOTE: If you do not recertify on time annually you will
be placed on an alternative repayment plan. The payments made while on the alternative repayment plan
are not PSLF eligible.
Income-Based Repayment (IBR) plan (not available for parent Direct PLUS Loans or Direct
Income-Contingent Repayment (ICR) plan (not available for parent Direct PLUS Loans or Direct
Standard Repayment plan with a 10-year repayment period
Any other Direct Loan Program repayment plan; but only payments that are at least equal to the monthly
payment amount that would have been required under the Standard Repayment Plan with a 10-year
repayment period may be counted toward the required 120 payments.
definition of "public service organization" for purposes of the PSLF Program are listed below.
A government organization (including a federal, state, local or tribal organization, agency, or entity;
a public child or family service agency; or a Tribal college or university);
A non-profit, tax-exempt organization* under Section 501 (c)(3) of the Internal Revenue Code (includes most
not-for-profit private schools, colleges, and universities);
A private, non-profit organization* (that is not a labor union or a partisan political organization) that
Emergency management
Military service
Public safety
Law enforcement
Public interest law services
Early childhood education (including licensed or regulated child care, Head Start, and State-funded
prekindergarten)
Public service for individuals with disabilities and the elderly
Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-time professionals
engaged in health care practitioner occupations and health support occupations)
Public education
Public library services
School library service, or other school-based services
*NOTE: For purposes of the full-time requirement (Section 3, Item 7 of the ECF), your qualifying employment does not
include time spent on job duties that are related to religious instruction, worship services, or any form of proselytizing.
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We reviewed the Public Service Loan Forgiveness {PSLF) Employment Certification form {ECF) you
submitted and determined that you may not participate in employment and payment tracking for the
PSLFprogram at this time. Your employment dates listed on the ECFwere prior to October 1, 2007.
Only dates of employment on or after October 1, 2007 at a qualifying public service organization can be
considered for the PSLFprogram.

If you were employed at a public service organization on or after October 1, 2007, please submit a
completed ECFwith eligible dates of employment.

our website MyFedLoan.org/PSLF.

WHAT HAPPENSAFTER I MAKE ALL REQUIRED PAYMENTS AND SUBMIT AN APPLICATION FOR
FORGIVENESS?

PSLFrequirements.

are listed below.
{includes most not-for-profit private schools, colleges, and universities);
• Public safety
• Law enforcement
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We reviewed the Public Service Loan Forgiveness (PSLF) Employment Certification form (ECF) you
submitted and determined that you may not participate in employment and payment tracking for the
PSLF Program at this time. Your employment dates listed on the ECF were prior to the disbursement
date of your Direct Loans eligible for PSLF. Only dates of employment at a qualifying public service
organization on or after the disbursement of your loans can be considered for the PSLFProgram.
WHAT DO YOU NEED TO DO

If you would like to further pursue the PSLF Program and have been employed full time at a public
service organization on or after the disbursement date of your eligible Direct Loans, please submit a
completed ECFwith eligible dates of employment.
THINGS TO REMEMBER
Although we will maintain copies of any documents that we receive, we recommend that you keep
copies of all forms that you submit and any supporting documentation regarding your employment and
the PSLFProgram. We also recommend that you submit an ECF annually so that we can update you on
your progress toward your forgiveness eligibility date. The ECFand additional information regarding the
program can be found on our website at www.MyFedLoan.org/PSLF.

If you have any questions, our trained PSLFspecialists are here to help. Contact us at the number above
or visit our website MyFedloan.org/PSLF.

PSLFrequirements.
AM I ENSUREDOF OBTAINING FORGIVENESSONCE I SATISFYALL PSLFREQUIREMENTS?

WHAT ARE THE ELIGIBILITYCRITERIAFOR PARTICIPATION IN THE PSLFPROGRAM?

are listed below.
• Public safety
• Law enforcement
occupations)
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Date
Borrower Name
Address Line 1
Address Line 2
WHY WE ARE CONT ACTING YOU

We received your faxed Employment Certification Form for Public Service Loan Forgiveness. The form received is
illegible; therefore, we were unable to process this correspondence.

You will need to resubmit a completed ECFif you wish to be considered for participation in the PSLFProgram.
Please ensure your employer reads and completes the Certification of Employment Section in its entirety. Mail or
fax this information to us again at the address or fax number listed above.
Employer certifications that are not provided in strict accordance with the ECFinstructions may result in delayed
Failure to provide a valid Employer Identification Number (EIN)
Misrepresentation under Type of Public Service Organization

If you have any questions, our trained PSLFspecialists are here to help. Contact us at the number above or visit our
website MyFedloan.org/PSLF.

Submission of an ECFform allows us to determine whether you meet the criteria for us to begin tracking your qualifying
PSLFemployment and payments. You must first make 120 separate, on time, full monthly payments prior to applying for
forgiveness. At that time, a forgiveness application will be available. No partial forgiveness is available for making less
than 120 payments.
WHAT HAPPENSAFTERI MAKE ALL REQUIREDPAYMENTSAND SUBMIT AN APPLICATIONFOR FORGIVENESS?

You must continue full-time employment with an approved public service organization while making qualifying payments
until the date that your loan(s) are actually forgiven.

While you may prepay your account, prepayments generally do not count toward more than one eligible payment. You
should make your normal installment payment each month while you are completing PSLFrequirements.

In order to benefit from PSLF,most of your qualifying payments must be made under the Income-Based Repayment (IBR),
Pay As You Earn(PAYE),Revised Pay As You Earn (REPAYE)or Income Contingent Repayment (ICR) Plans. However, you
will pay more interest over time under these repayment plans if you do not ultimately qualify for PSLF.
You must be employed full-time (in any position) by a public service organization or must be serving in a full-time
definition of "public service organization" for purposes of the PSLFProgram are listed below.
• A government organization (including a federal, state, local or tribal organization, agency or entity; a
public child or family service agency; or a Tribal college or university);
•Anon-profit, tax-exempt organization* under Section 501(c)(3) of the Internal Revenue Code (includes
most not-for-profit private schools, colleges, and universities);
• A private, non-profit organization* (that is not a labor union or a partisan political organization) that
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated child care, Head Start, and State-
funded prekindergarten)
professionals engaged in health care practitioner occupations and health support occupations)
*Note: For purposes of the full-time requirement (Section 3, Item 2.(b) of the ECF),your qualifying employment
does not include time spent on job duties that are related to religious instruction, worship services, or any form
of proselytizing.
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recently submitted. You checked the box indicating you were unable to obtain certification from an
authorized official. However, we determined that your organization is still operational. As a result, an
authorized official must complete the certification section on the ECF. We will consider your previously
submitted ECFclosed.

You will need to resubmit a completed ECF if you wish to be considered for participation in the PSLF
Program. Please ensure your employer reads and completes the employment and employer
certification sections in their entirety.
Employer certifications that are not provided in strict accordance with the ECFinstructions may result in
delayed processing or denial of your ECF. Common mistakes in the employment and employer
certification sections include:
Misrepresentation of the type of organization that employs you



PSLFrequirements.

are listed below.
• Public safety
• Law enforcement
occupations)
Public Service Loan Forgiveness:

Questions and Answers for Federal Student Loan
Borrowers
Contents
Introduction ............................................................................................................................................................................. 1
General Information ................................................................................................................................................................ 2
Eligible Loans ......................................................................................................................................................................... 2
Qualifying Repayment Plans .. .3
Qualifying Payments ............................................................................................................................................................... 5
Qualifying Employment .......................................................................................................................................................... 7
Application Process .............................................................................................................................................................. 11
Introduction
The following questions and answers (Q&As) provide information about public service loan forgiveness. Throughout the
Q&As, we use the following terms:
• ED refers to the U.S. Department of Education.
• We means either ED or FedLoan Servicing, the servicer that is responsible for administering the Public Service
Loan Forgiveness (PSLF) Program on behalf of ED.
• Direct Loan Program refers to the William D. Ford Federal Direct Loan Program. This program includes Direct
Subsidized Loans, Direct Unsubsidized Loans, Direct PLUS Loans, and Direct Consolidation Loans. Direct
Subsidized Loans and Direct Unsubsidized Loans are sometimes called "Stafford Loans."
• FFEL Program refers to the Federal Family Education Loan Program. This program includes Subsidized Federal
Stafford Loans, Unsubsidized Federal Stafford Loans, Federal PLUS Loans, and Federal Consolidation Loans.
No new loans have been made under this program since July 1, 2010.
• Perkins Loan Program refers to the Federal Perkins Loan Program. This program includes Federal Perkins
Loans, National Direct Student Loans, and Defense Student Loans.
• Income-driven repayment plan refers to a repayment plan that bases your payment amount on your income
instead of how much you owe. The following repayment plans are income-driven plans: The Revised Pay As You
Earn Plan (REPAVE Plan), the Pay As You Earn Plan (PAYE Plan), the Income-Based Repayment Plan (IBR
Plan), and the Income-Contingent Repayment Plan (ICR Plan).
• Loan servicer refers to the organization that collects your loan payments and completes other transactions
related to your federal student loans. Your loan servicer may or may not be the same organization as your loan
holder (the organization that "owns" your loans). If you are unsure who your loan servicer is, you can find this
information using "My Federal Student Aid" at StudentAid.gov/login, or you can call the Federal Student Aid
Information Center (FSAIC) at 1-800-4-FED-AID (1-800-433-3243; TTY 1-800-730-8913).
Federa IStudent PROUD SPONSOR of

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Page 1 FEDERATION
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN of 13 OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
General Information
General Information
1. What is the Public Service Loan Forgiveness (PSLF) Program?

The PSLF Program was established to encourage individuals to work in public service by forgiving the
remaining balance of their Direct Loans after they have made 120 qualifying payments while employed by
a qualifying employer.
2. What are the eligibility requirements for loan forgiveness under the PSLF Program?
You must be employed full-time by a qualifying employer when you make each of the required 120
qualifying payments on your Direct Loans, and also at the time you apply for loan forgiveness after
making the last of those 120 payments, and when you receive loan forgiveness.
3. Are loan amounts forgiven under PSLF considered taxable by the IRS?
No. According to the Internal Revenue Service (IRS), student loan amounts forgiven under PSLF are not
considered income for tax purposes. For more information, check with the IRS or a tax advisor.
4. Does my income level determine eligibility for PSLF?

There is no income requirement to qualify for PSLF. However, since your required monthly payment
amount under most of the qualifying PSLF repayment plans is based on your income, your income level
over the course of your public service employment may be a factor in determining whether you have a
remaining loan balance to be forgiven after making 120 qualifying payments.
5. Can I be certain that the PSLF Program will exist by the time I have made my 120
qualifying payments?
We cannot make any guarantees about the future availability of PSLF. The PSLF Program was created
by Congress, and Congress could change or end the PSLF Program.
Eligible Loans
6. I have federal student loans from a program other than the Direct Loan Program. Can I
qualify for PSLF?
PSLF is available only for Direct Loans. However, if you have loans made under another federal student
loan program, you may consolidate those loans into a Direct Consolidation Loan, which is eligible for
PSLF. To apply for a Direct Consolidation Loan, visit Studentloans.gov.
Note: Any payments you've made on your loans from other federal student loan programs before you
consolidate them into the Direct Loan Program will not count toward PSLF, even if they were made under
a qualifying repayment plan.
Learn more about loan consolidation at StudentAid.gov/consolidation.
Federal Student Aid I StudentAid.gov Page 2 of 13
Qualifying Repayment Plans
7. I consolidated my Direct Loans after I made qualifying PSLF payments on those loans.
Do the payments I made before consolidation still count toward PSLF?
No. Payments that you made on Direct Loans prior to consolidation do not count toward the 120 required
payments for PSLF. You will need to make 120 qualifying payments on the new Direct Consolidation
Loan. For this reason, if you have made qualifying PSLF payments on your Direct Loans and you are
thinking of consolidating those loans into a Direct Consolidation Loan along with loans you received under
other federal student loan programs, you should leave your Direct Loans out of the consolidation and
consolidate only your loans from other federal student loan programs.
8. Are private education loans eligible for PSLF?

No. Private education loans are not eligible for PSLF and cannot be consolidated into a Direct
Consolidation Loan.
9. Are Direct Loans that are in default eligible for PSLF?

No. Defaulted Direct Loans are not eligible for PSLF. However, a defaulted loan may become eligible for
PSLF if you resolve the default. To learn more about getting your loan out of default, visit
StudentAid.gov/end-default.
I 0. Can a joint FFEL Consolidation Loan that I obtained with my spouse be consolidated
into a Direct Consolidation Loan so that one or both of us can qualify for PSLF?
No. The law no longer permits joint consolidation loans to be made, so joint FFEL Consolidation Loan
borrowers may not jointly reconsolidate their FFEL Consolidation Loan into a Direct Consolidation Loan.
In addition, a borrower may not individually reconsolidate a joint FFEL Consolidation Loan into a new
Direct Consolidation Loan to take advantage of PSLF.
11. Are Direct PLUS Loans eligible for PSLF?

Yes. Like other Direct Loans, Direct PLUS Loans are eligible for PSLF. However, there are additional
factors to consider if you are a parent who has taken out a PLUS loan.
First, your PSLF eligibility is based on your qualifying employment, not on the employment of the
dependent student on whose behalf you borrowed. Second, PLUS loans received by parents may not be
repaid under the income-driven plans, the repayment plans that are best for borrowers seeking PSLF.
However, if you consolidate a PLUS loan that you took out on behalf of your child, you may then repay
the new Direct Consolidation Loan under the ICR Plan (but not the REPAVE, PAYE, or IBR plans).
Note: PLUS loans made to graduate and professional students may be repaid under any of the income-
driven plans.
12. What Direct Loan Program repayment plans qualify under the PSLF Program?
To count toward PSLF, payments must be made under one or more of the following repayment plans:
• Any income-driven repayment plan
• The 10-Year Standard Repayment Plan
• Any other plan with payments that are at least equal to the monthly payment amount you would be
required to pay under the 10-Year Standard Repayment Plan
Learn about your repayment plan options at StudentAid.gov/repay-loans-understand/plans.
13. What is the best repayment plan if rm seeking PSLF?

An income-driven plan is your best option.
Although the 10-Year Standard Repayment Plan qualifies for PSLF, it requires you to fully pay off your
loan within 1O years (120 monthly payments). Therefore, you will not have any remaining loan balance to
be forgiven if you make all of your 120 qualifying payments under the 10-Year Standard Repayment Plan.
The 10-Year Standard Repayment Plan and other plans with payments that are equal to the 10-Year
Standard Repayment Plan amount are included as eligible repayment plans for PSLF purposes so that
borrowers may receive credit toward the required 120 PSLF payments for any payments they may have
made under those plans before switching to an income-driven plan.
14.1 m repaying my Direct Consolidation Loan under the Standard Repayment Plan. Does
that plan qualify for PSLF?
Generally, no. The Standard Repayment Plan for Direct Consolidation Loans is not the same repayment
plan as the 10-Year Standard Repayment Plan, and payments made under the Standard Repayment
Plan for Direct Consolidation Loans do not usually qualify for PSLF purposes.
Under the Standard Repayment Plan for Direct Consolidation Loans, the maximum repayment period
may be up to 30 years, depending on the amount of the consolidation loan and the amount of your other
education loan debt. This longer repayment period generally results in a lower monthly payment than the
monthly payment amount required under the 10-Year Standard Repayment Plan.
If you're seeking PSLF, the best option would be to repay your Direct Consolidation Loan under an
income-driven repayment plan.
15. What other Direct Loan repayment plans would give me a monthly payment that is at
least equal to the payment that would be required under a 10-Year Standard
Repayment Plan?
Under the Graduated Repayment Plan, payments start out lower and then gradually increase, generally
every two years. Therefore, payments made during the later portion of the repayment period under the
Graduated Repayment Plan may in some cases equal or exceed the payment amount that would be
required under a 10-Year Standard Repayment Plan, and these payments would count for PSLF.
16. If I'm repaying my Direct Loans under the PAYE or IBR Plan and my monthly payments
are no longer based on my income, will my payments continue to count for PSLF?
Yes. Although you will always initially have a payment based on your income in the PAYE and IBR plans,
under certain circumstances your monthly payment under those plans may no longer be based on
income. However, your monthly payments will continue to qualify for PSLF if you remain on the PAYE or
IBR plan.
FederalStudent Aid I StudentAid.gov Page 4 of 13
Qualifying Payments
17. I'm in the process of rehabilitating a defaulted Direct Loan. Will my rehabilitation
payments count toward PSLF?
No. Payments made to rehabilitate a defaulted Direct Loan do not qualify for PSLF
Qualifying Payments
18. What is a qualifying payment for the PSLF Program?

To receive PSLF, you must have made 120 qualifying payments on the Direct Loans for which you are
seeking forgiveness. A qualifying payment is a payment that was
• made after October I, 2007;
• received no later than 15 days after your due date;
• for the full amount due that month;
• made under a qualifying repayment plan; and
• made while you were employed full-time by a qualifying employer.
19. Do I need to make consecutive payments to qualify for PSLF?

No. The 120 payments do not have to be consecutive payments, but you must be employed by a
qualifying employer at the time you make each payment.
20. If I pay more than my scheduled monthly student loan payment amount, can I get PSLF
sooner than IO years?
No. You must make 120 separate monthly payments. Paying extra will not make you eligible to receive
PSLF sooner.
If you make a payment for more than the scheduled payment amount, the excess amount may be applied
to cover all or part of one or more future payments, unless you request otherwise. Depending on how
much extra you pay, it's possible that your next due date could be a month or more in the future from the
date you made the extra payment amount. If you make subsequent payments during a period when you
are not required to make a payment (that is, when your account is paid ahead), those payments will not
count toward PSLF.
If you request that your extra payment amount not be applied to future scheduled payments, the excess
amount will not advance the due date of your next scheduled payment, and any subsequent monthly
payments you make can count toward the required 120 payments.
21. If I return to school and qualify for an in-school deferment on my Direct Loans that are in
repayment. can I decline the deferment and make qualifying PSLF payments while I'm
in school?
Yes. You may decline an in-school deferment on your loans that are in repayment status and make
qualifying payments on those loans while you are in school. Remember, in order for your payments to
qualify for PSLF, you must be employed full-time by a public service organization while you attend school.
Note: If you receive new Direct Subsidized Loans or Direct Unsubsidized Loans when you return to
school, you will not be able to make qualifying PSLF payments on those loans while you are in school.
Any new Direct Subsidized Loans or Direct Unsubsidized Loans you receive will not enter repayment until
Qualifying Payments
the end of the six-month grace period. Although you could voluntarily make payments on your new Direct
Subsidized Loans and Direct Unsubsidized Loans while you are in school or during your grace period,
those payments would not count toward PSLF.
22. Can I waive the six-month grace period on my Direct Subsidized Loans and Direct
Unsubsidized Loans and begin making qualifying PSLF payments early?
No. The law that governs the Direct Loan Program does not allow borrowers to waive the grace period on
Direct Subsidized Loans and Direct Unsubsidized Loans. You cannot begin making qualifying PSLF
payments until after your loans have entered repayment at the end of the grace period. Any payments
you make on a loan during the grace period will not count toward PSLF.
However, if you want to immediately begin making qualifying payments on your federal student loans as
soon as you leave school, you may consolidate your loans into a Direct Consolidation Loan during your
grace period and enter repayment right away.
23. l"m thinking of serving as a Peace Corps or AmeriCorps volunteer and plan to request a
deferment or forbearance on my Direct Loans. If l"m not making payments during my
service period, can I receive credit toward PSLF?
If you receive a deferment or forbearance during your volunteer service, you can use the transition
payment you receive after completing your period of Peace Corps service or the Segal Education Award
you may receive after AmeriCorps service to make a lump-sum payment on your Direct Loans. If you use
some or all of your Peace Corps transition payment or AmeriCorps Segal Education Award to make a
lump-sum payment on your Direct Loans, you will receive credit for up to 12 qualifying payments for
PSLF. The number of payments for which you receive credit is determined by dividing the amount of your
lump-sum payment by your scheduled full monthly payment amount, but you may not receive credit for
more than 12 monthly payments toward the PSLF payment requirement. This benefit is available to you
only one time for Peace Corps service and one time for AmeriCorps service. However, there is an
alternative that you may want to consider.
As an alternative to receiving a deferment or forbearance during your volunteer service and then using
your Peace Corps transition payment or Segal Education Award to make a lump sum payment on your
loans, you could choose to not request a deferment or forbearance and instead make qualifying PSLF
payments during your volunteer service. If you repay your Direct Loans under an income-driven plan,
your required monthly payment is likely to be an amount that you can afford even while you are
performing volunteer service and receiving very little income. For some borrowers, the required monthly
payment amount under one of these repayment plans may be $0.
If you do not request a deferment or forbearance and instead make payments under an income-driven
plan during your Peace Corps or AmeriCorps service, you may be able to receive credit for a larger
number of qualifying PSLF payments than you would if you received a deferment or forbearance and then
used your Peace Corps transition payment or Segal Education Award to make a lump-sum payment on
your Direct Loans. This is because you can receive credit for a maximum of only 12 qualifying payments if
you make the lump-sum payment, but each payment you make under the income-driven plan (including a
scheduled payment amount of $0) while you are serving as a full-time Peace Corps or AmeriCorps
volunteer counts as a qualifying PSLF payment if it meets all of the requirements described elsewhere in
this document.
FederalStudentAid I StudentAid.gov Page 6 of 13
24. If my scheduled monthly payment under an income-driven plan is SO, does each month
during which my payment is SOcount toward the required 120 separate, monthly
payments?
Yes. Any month when your scheduled payment under an income-driven plan is $0 will count toward PSLF
if you also are employed full-time by a qualifying employer during that month.
25. If I make payments more frequently than monthly (for example. twice each month, when
I get paid). will my payments count toward PSLF?
If you make multiple partial payments that total at least your monthly payment amount, and you make
those payments no later than 15 days after the scheduled payment due date for that month's payment,
the series of partial payments will count as a one qualifying payment for PSLF.
For example, if your required monthly payment is $200 and you make two $100 payments no later than
15 days after your due date, you would receive credit for one qualifying payment.
26. What types of employers are qualifying employers for the PSLF Program?
All federal, state, local, or tribal government agencies or organizations, and many not-for-profit
organizations, are qualifying employers for PSLF.
27. What counts as a government employer for the PSLF Program?

In addition to any federal, state, local, or tribal government agency, eligible government employers for the
PSLF Program include the U.S. military, public elementary and secondary schools, public colleges and
universities, public child and family service agencies, and special governmental districts (including entities
such as public transportation, water, bridge district, or housing authorities).
View a listing of most government agencies and departments at USA.gov.
Note: Service as an elected member of the U.S. Congress is not qualifying employment for PSLF.
28. What not-for-profit organizations qualify as eligible employers for the PSLF Program?
Eligible not-for-profit organizations include
• those that are tax-exempt under section 501 (c)(3) of the Internal Revenue Code, and
• those that are nottax-exempt under section 501 (c)(3) of the Internal Revenue Code, but provide a
qualifying public service.
However, if the organization is a labor union or a partisan political organization, it is not an eligible PSLF
employer. In addition, if you perform religious activities as part of your job, there are limitations on your
ability to have your employment qualify for PSLF.
Eligible not-for-profit organizations include most private elementary and secondary schools, private
colleges and universities, and thousands of other organizations. Your employer can tell you if it is a not-
for-profit organization and what its tax status is, or you can use the searchable database of tax-exempt
organizations at www.lRS.gov.
A not-for-profit organization that is not exempt under section 501 (c)(3) of the Internal Revenue Code must
provide one of the following public services:
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated childcare, Head Start, and state-funded
pre-kindergarten)
professionals engaged in health care practitioner occupations and health care support occupations)
• School library or other school-based services
29. I'm employed full-time by a qualifying not-for-profit organization. but my Job duties
include religious activities. Does my employment qualify for PSLF?
It depends on how much of your job is related to religious activities. When determining whether you are a
full-time employee for PSLF, your employer may not include the time you spend participating in religious
instruction, worship services, or any form of proselytizing.
30. What types of public service Jobs will qualify me for loan forgiveness under the PSLF
Program?
The specific job that you perform does not matter, as long as you are employed by an eligible public
service organization. For example, if you are a full-time employee of a public school system, your
employment would meet the requirements for PSLF, regardless of your position (teacher, administrator,
support staff, etc.).
31. What is considered full-time employment for PSLF?

If you only have one employer, you must meet your employer's definition of full-time. However, for PSLF
purposes, that definition must be at least 30 hours per week.
32.1 am a teacher who does not teach over the summer break. If I make payments during
the summer. do those payments count toward PSLF?
Payments you make during the summer will count if you have a contract for an employment period of at
least eight months and you work an average of 30 hours per week during that period, and if your
employer still considers you to be employed full-time during the summer break. Of course, the payments
must otherwise meet all PSLF requirements. In this circumstance, your employer should include the dates
of the summer break when reporting your dates of employment on the PSLF Employment Certification
Form, even though you are not actually teaching during that period.
33. I'm working for more than one employer during the same period of time. but I'm not
employed by any one of them on a full-time basis. Will my combined employment be
considered full-time for PSLF?
Yes, as long as the combined number of hours you work for each employer equals at least 30 hours per
week. Each employer must be a qualifying employer for the employment to be included in determining
whether you are employed on a full-time basis.
For example, if you worked for one qualifying employer for 10 hours per week and you concurrently
worked for a second qualifying employer for 20 hours per week, this would meet the 30 hours per week
requirement.
34. ls Peace Corps or AmeriCorps service considered qualifying employment for PSLF?
Yes, if you are serving as a full-time Peace Corps or AmeriCorps volunteer.
35. I'm employed full-time by a company that is doing work for a qualifying PSLF employer
under a contract. However, the company that I work for is not a qualifying PSLF
employer. Does this employment qualify for PSLF?
No. You must be employed full-time by a qualifying employer.
36. I know that employment with a public school qualifies for PSLF. What about
employment with a private school?
Most private elementary and secondary schools, and private colleges and universities are not-for-profit
organizations. If a private school has this status, it would qualify as a public service organization for PSLF
purposes.
However, employment with a private school, college, or university that operates on a for-profit basis is not
eligible employment for PSLF purposes.
37. Can I receive PSLF if I have more than one employer over the course of IO years?
Yes. However, you must provide documentation that demonstrates that you were employed full-time by a
qualifying employer at the time you made each of the required 120 payments.
38. If I'm employed by a 501 (c)(3) organization. but I work outside the United States, would
the employment qualify under the PSLF program?
Yes. Full-time employees of 501 (c)(3) organizations may perform their work anywhere.
39.1 ma full-time employee of a foreign not-for-profit organization that is not a 501 (c)(3)
organization. Will my employment with this not-for-profit organization qualify for PSLF?
It depends on whether the organization operates in the United States.
If the organization operates in the U.S., your employment would qualify for PSLF purposes. If the
organization does not operate in the U.S., your employment does not qualify.
40. Does employment by a foreign government or international. intergovernmental

organization (such as the United Nations. Organization for Economic Cooperation and
Development. Organization of American States. North Atlantic Treaty Organization)
qualify for PSLF?
No. Only U.S. federal, state, local and tribal government organizations, agencies, or entities qualify as
public service organizations for purposes of PSLF. However, if you work for a U.S. delegation to an
international, intergovernmental organization, such as the U.S. mission to the United Nations, your
employment qualifies because your employer is the U.S. government.
41. l"m employed full-time by an eligible public service organization in one of the islands
that have a legal relationship with the United States. Will that employment qualify for
PSLF purposes?
Yes. American Samoa, the Commonwealth of Puerto Rico, Guam, the Virgin Islands, the Commonwealth
of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of
Micronesia, and the Republic of Palau are considered part of the United States for PSLF.
42. Does full-time volunteer service for a public service organization qualify for PSLF?
No. Unless you are an AmeriCorps or Peace Corps volunteer, you must be a full-time employee who is
hired and paid by a public service organization.
43.1 am serving a fellowship with a qualifying employer. Does this qualify for PSLF?
It depends on the terms of your fellowship. It would qualify only if you are considered an employee who is
hired and paid by the public service organization where you are serving the fellowship.
44. Are vacation and leave periods considered when determining whether I am a full-time
employee?
Vacation or leave time provided by your employer is counted as hours worked in determining whether you
meet the full-time employment requirement. This includes leave taken for a qualifying condition under the
Family and Medical Leave Act of 1993.
45.1 m the only official who can certify my employment. Can I certify my own qualifying
employment?
Yes, you may certify your own employment if you are the only employee of the organization who can do
so. However, we will request additional documentation concerning your employment, such as earnings
statements, IRS W-2 forms, your application for tax-exempt status, or any other documentation required
to be filed with the IRS on a periodic basis regarding the activities of the organization.
46. What if I make my last qualifying payment while working for a qualifying employer. but
then leave that job to work for a for-profit corporation before applying for the PSLF
benefit. Am I still eligible for PSLF?
No. To be eligible for forgiveness after making 120 qualifying payments, you must be employed full-time
by a qualifying employer at the time you made each qualifying payment, at the time you apply for loan
forgiveness, and at the time you receive loan forgiveness.
Application Process
Therefore, if you leave your job at a qualifying employer after meeting the PSLF eligibility requirements
but before you apply for loan forgiveness, you would not be eligible for forgiveness since you must be
working for a qualifying employer at the time you apply for and receive forgiveness. However, you could
regain eligibility if you later find full-time employment at another qualifying public service organization and
then apply for loan forgiveness.
Application Process
47. How can I find out if my employment and payments qualify for PSLF?
If you submit the PSLF Employment Certification Form at
https://studentaid.ed.gov/sa/sites/default/files/public-service-employment-certification-form.pdf,
we will tell you if your employment and payments qualify for PSLF. You are encouraged to submit this
form to FedLoan Servicing, our PSLF servicer, annually while you are working to fulfill the requirements
for PSLF so that you will receive feedback on the eligibility of your employment and payments on an
ongoing basis.
After you submit your first Employment Certification Form, and if our PSLF servicer determines that your
employment qualifies, all of your loans owned by the U.S. Department of Education will be transferred to
the PSLF servicer, which will then verify that the loan payments you made during the period covered by
the Employment Certification Form are qualifying payments. After reviewing your Employment
Certification Form, the PSLF servicer will tell you how many qualifying payments you have made toward
PSLF.
48. After I submitted the Employment Certification form. I was notified that I would now have
a different servicer for my federally held student loans. Why did my servicer change?
One of the federal loan servicers, FedLoan Servicing, has been assigned the responsibility of
administering PSLF for all Direct Loan borrowers. As a result, if you submit an Employment Certification
Form and FedLoan Servicing determines that your employment qualifies, all of your Direct Loans as well
as any of your FFEL Program loans that are held by ED will be transferred to FedLoan Servicing.
49. What kind of documentation do I need to keep to show that I worked for a qualifying
PSLF employer while making the required 120 payments on my Direct Loan(s)?
The PSLF servicer will confirm that your employer is a qualifying public service organization based on the
information provided on the Employment Certification Form that you submit. In some cases, the PSLF
servicer may require additional documentation about your qualifying employment. Therefore, you should
keep records that identify your employer, show your dates of employment with that employer, confirm that
you were a full-time employee, and demonstrate that your employer meets the definition of a public
service organization. Examples of such documents include, but are not limited to, IRS W2 forms and pay
stubs.
You should retain as many documents supporting your qualifying employment as possible.
50. What should I do after I qualify for PSLF?

You must submit an application for Public Service Loan Forgiveness.
Please note that the earliest any borrower will be able to qualify for Public Service Loan Forgiveness is
October 2017. Therefore, there is no application for forgiveness yet. The application will be released
closer to the time when the first borrowers will qualify for forgiveness.
Application Process
51. When l"m ready to submit my loan forgiveness application. do I need to submit any
other documents to the PSLF servicer?
Yes. Even if you submitted Employment Certification Forms to the PSLF servicer during the entire period
when you were making your 120 qualifying payments, you will need to submit one additional Employment
Certification Form to verify that you are employed full-time with a qualifying public service organization at
the time you submit your PSLF application.
If you did not submit any Employment Certification Forms, did not submit forms for some of your
employers, or submitted forms for only a portion of your period of qualifying employment, you will need to
provide one or more Employment Certification Forms, as necessary, to cover your entire period of
qualifying employment (including your current employment) at the time you submit your loan forgiveness
application.
52.1 made some qualifying payments. but I no longer work for my qualifying employer and
do not think I will work in qualifying employment again. Can I receive partial forgiveness
based on the number of qualifying payments that I made?
No. There is no partial loan forgiveness. To receive PSLF, you must make all 120 qualifying payments
while working for a qualifying employer.
53. When I submit my application for loan forgiveness after making the required 120
qualifying payments. how long will it take to process my application and forgive my
remaining loan balance?
Processing times will vary depending on factors such as whether you previously submitted documentation
of employment for review or submitted documentation only at the time you applied for loan forgiveness,
the number of your employers, any gaps in your employment or payment history, and any required follow-
up.
If you periodically submitted the Employment Certification for Public Service Loan Forgiveness Form so
that your eligibility could be tracked while you were making the required 120 payments, your application
for loan forgiveness will likely be processed more quickly.
The PSLF servicer will notify you that you are not required to continue making payments on your loans
during the period when your loan forgiveness application is being processed.
54. What will happen if my PSLF application is denied?

If we determine that you are not eligible for loan forgiveness, you will be notified of this determination and
will be provided with the reason you were determined to be ineligible. Fedloan Servicing, ED's PSLF
servicer, will then resume billing on your loans.
The PSLF servicer will also grant forbearance of payments of principal and interest to cover the period
when collection activity was suspended during the application processing period. If you are not granted
forgiveness, interest that accrues (accumulates) during a period of suspended collection activity may be
capitalized.
Capitalization means that we add accrued interest to the unpaid principal amount of your loan.
Capitalization increases the unpaid principal balance of your loan, and we will then charge interest on the
increased principal amount.
Application Process
55. If I receive loan forgiveness under the federal Teacher Loan Forgiveness Program after
completing five years of qualifying teaching service, will I also be able to qualify for
PSLF?
Yes. However, you may not receive a benefit under both the Teacher Loan Forgiveness Program and the
Public Service Loan Forgiveness Program for the same period of teaching service. For example, if you
make payments on your loans during your five years of qualifying employment for Teacher Loan
Forgiveness and then receive loan forgiveness for that service, the payments you made during that five-
year period will not count toward PSLF.
56. If I m employed by a qualifying employer and receive a student loan repayment benefit
from my employer under the Federal Student Loan Repayment Program or under
another employer-based student loan repayment program. can I also receive PSLF
based on the same employment?
Yes. You may receive benefits under both an employer loan repayment plan, including the Federal
Student Loan Repayment Program and the PSLF Program for the same period of qualifying public
service.
Note: If your employer makes a single lump-sum payment that covers multiple monthly student loan
payments, it will count as only one qualifying monthly payment and may affect whether future payments
qualify.
Learn more about the Federal Student Loan Repayment Program at www.opm.gov/policy-data-
oversightlpay-leave/student-loan-repayment.
December 2015
fedloan-
~·SERVICING
FJX 717-720-1628
www.MyFedLoon org

1\DUR[SS Llf\[ 1
1\DUR[SS Llf\[ 2


We received the Public Service Loan Forgiveness (PSLF) Employment Certification Form (ECF)you
recently submitted. You checked the box indicating you were unable to obtain certification from an
authorized official.

Since the organization that employed you is no longer operational, you must submit the following in
order for us to establish your eligibility for the PSLFProgram:
• IRS Form W-2 Wage and Tax Statement from each tax year of your employment with the
organization
• Paystubs received during the dates of employment with the organization indicated on the ECFas
confirmation of the number of hours you worked per week at that employer
Please also review the Eligibility Criteria on the reverse of this letter.


FORGIVENESS?

PSLF requirements.


are listed below.
• Public safety
• Law enforcement
occupations)
From: kbJ/5]
To: Fed Loan "SLF. D1aro Fro,ndol
Cc: R,ttle C'/ntl1'/: ohns;,n ret;be: FLlh.l.arr: kbJ/5]
Subject: (external] ~E: Bar Association of San Francisco
Date: 02/2712015 02:33 Pl,•I
Attachments: PSLF AILI, zo·4·z,c- Fml 14).pdf
Hi Diane,
(b)(5)
Please let me know if you need additional 1nformat1on on this decision.
HJve J good weekend
Taneka
-----Or1ginJI Message--
From· D1Jne Freundel [mailto dfreunde@pheJa org] On BehJlf Of FedLoan PSLF
Sent: Thursday, February 19, 2015 2:07 PM
To l{b)(5) I
Cc: BJttle, Cynthia; Johnson, Debbe: Fedloan PSLF;Foss, Ian
SubJecl: Re: Bar Assoc1al1onof San Franrnw
Hi everyone, We just received d follow-up letter from this employer

(attached - no NPPI, so no need to password protect). We still don't
believe they quJl1fy, but since you've already provided input on this employer, we'd like you to review.
ThJnks for your help I
(See attached file Additional Documentation - Dispute letter pdf)
Diane Freundel
Compl1Jnce Services
(717) 720-3267
dfreunde@pheao or~
5
From: !(b)(5) l[b)( l
To: "Fedlodn PSLF"<Eedl oanPSI F@phead orp
Cc: "BJttle, Cynth1J" <Cynthia BJttle@ed gov>, "Johnson. Debbe"
<D hn n oJ v>, "Foss, Ian' <lan.Foss(riled.gov>,
l{b)(5) I b)(5)
Date: 02/11/2014
SubJecl: Re: Bar Assoc1al1onof San Franc1sw
receive this messJge 1n error please delete or destroy this messJge

Jnd/or attachments.
The sender of this messJge will fully cooperate 1nthe civil and
u1m1nal prosetul1on of any 1ndiv1dualengaging
1nthe unJuthomed use of this message
This message contains privileged and conf1dent1al 1nformat1on intended for the above addressees only. If you receive this message 1n
error pleJse delete or destroy this message Jnd/or attachments.
The sender of this messJge will fully cooperJte 1nthe civil Jnd rnm1nJI prosecution of Jny 1ndiv1dualengJg1ng 1nthe unauthorized use
of this message.
H1Diane,
b)(5)
At least, thJt's my understJnd1ng based on some IRS literJture I found
lac
On 1/23/14, 21 20, "Fed Loan PSLF"<Eedl oanPSI E@pheao ocp wrole:
Hi Ian, We reviewed the Bar Assoc1Jllon's Form 990 again and included
Schedule O and a page from Schedule R 1n the zip file.
Sthedule O lisls "We provide legal services to disadvantaged and

underserved 1nd1v1duJls1n San FrJnc1sco" as one of the Assoc1at1on's
missions.
Schedule R lists the Justice and Diversity Center 1n Part II -

ldent1f1cJtion or RelJted Tax-Exempl Organ1lJllons and shows Lhe 13Jr
AssociJtion JS the Direct Controlling Entity. But I don't understJnd
che
difference between a related tax-exempt organization (Part II of
Schedule
R) and a disregJrded entity (PJrt I of Schedule R).
We appreciate your help. PJssword to follow. ThJnks
(See attached file: Bar Assoc1at1onof San Francisco.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfreunde@PhPd<l org
0 )~_JI
From· ,kbcl,(5 <publ1cserv1ce@ed gov>
To: "Fedloan PSLF"<FedLoanPSLF(rilpheaa.org>
Cc: l{b)(5) l<publ1cserv1ce(iiled.gov>, "Battle, Cynthia"
<Cynth1a.Battle@led.gov>, "Johnson, Debbe"
<Debbe lohnson@ed gov>, "Foss, Ian' <Id □ Eoss@ed gov>
DJte· 01/22/2014 02 35 PM
Subject: Re· Bar Association of San Francisco
H1Diane,
It seems that the Justice Jnd Diversity Center spun off as J sepJrate
501(c)(3) organ1Lat1on (see here:
https :/!www.sfbar.org/1d c/1ndex a spx)
Is there anything else that 1nd1catesthat the organization provides
legal
services?
Sorry for the delay
Ian Foss
On 12/24/13, 13:27, "Fed Loan PSLF"<EedloaoPSI

E@PhParl
PCP wrole:
(b)(5)
(See attached rile: Bar Association of San Franusco.L1p)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfre1mde(ill oheaa.org
This messJge contJins privileged and conf1dent1JI 1nformJt1on
intended
for the above addressees only. If you
receive this message 1n error please delete or deslroy lh1s
message
Jnd/or attachments.
The sender of this message will fully cooperate 1nthe civil

Jnd criminal
prosecution of any individual engaging
1nthe unauthorized use of this message.
This message contains privileged and conf1dent1al 1nformat1on

intended for the above addressees only. If you
Federa IStudent J;:d PROUD SPONSOR of

tile AMERICAN MIND· DF..C
1 iJ 201-\
Dear Ms.~
In 2012, you corresponded with Ms. Maureen Dowling in the U.S. Department of Education's
{the Department's) Office of Innovation and Improvement concerning the status of your
employer, the American Immigration Lawyers Association (AILA), as a qualifying employer for
purposes of the Public Service Loan Forgiveness (PSLF) Program.
Under the PSLF Program, borrowers of federal student loans made under the William D. Ford
Federal Direct Loan Program (the Direct Loan Program) may qualify for forgiveness of their
remaining loan balance after they have made 120 qualifying payments while employed full-time
by an eligible public service organization. Under section 455(m) of the Higher Education Act of
1965, as amended [20 USC 1087e(m)], and the implementing PSLF Program regulations at 34
CFR 685.219(b), an eligible public service organization is a government entity, a public child or
family service agency, an entity that is tax-exempt under Section 501 (c)(3) of the Internal
Revenue Code (IRC), a tribal college or university, or a private not-for-profit organization that
provides certain types of public services as listed in paragraph {5)(i) of the definition of "public
service organization" in 34 CFR 685.219(b).
Ms. Dowling referred your question to staff at the Department's Federal Student Aid office and
Office of Postsecondary Education, both of which are responsible for the management and
oversight of the PSLF Program. Our preliminary review of your employer's status in 2012
suggested that AILA was a not-for-profit organization that provided public interest law services.
This would make AILA a qualifying employer for purposes of the PLSF Program. We relayed
this information to you through Ms. Dowling.
Earlier this year, another employee of AILA submitted an Employment Certification for Public
Service Loan Forgiveness form to FedLoan Servicing, the Department's designated federal
student loan servicer for borrowers who are seeking a determination of whether their
employment and payments qualify for the PSLF Program. Upon receipt of an Employment
Certification for Public Service Loan Forgiveness form, FedLoan Servicing is responsible for
officially determining whether the employer listed by a borrower on the form is a qualifying
employer tor purposes of the PSLF Program. In instances where FedLoan Serving cannot
clearly determine whether an employer qualifies, at least one Department of Education manager
performs an additional review and, if necessary, consults with the Department's Office of
General Counsel, before a final determination of the employer's status is made and
communicated to the borrower. This was the process used following receipt of the AILA
employee's submission of the Employment Certification for Public Service Loan Forgiveness
form to FedLoan Serving. Through this more thorough review process, we determined that
AILA is not a qualifying employer for purposes of the PSLF Program, for the reasons explained
below.
We determined that AILA is a private not-for-profit organization that is tax-exempt under section
501 (c)(6) of the IRC. Because AILA is not a tax-exempt entity under Section 501 (c)(3) of the
Internal Revenue Code, it can only qualify as an eligible employer for purposes of the PSLF
Program if it provides one of the public services listed in paragraph (5)(i) of the regulatory
definition of "public service organization." Qualifying types of public service that we considered
included public education and public interest law.
1
830 F•''ol Stre-~t. N[ Nasl11·-,g 1 ,::11 DC: ;202c;,~
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND Student.!'J,,rj g:.v

The Employment Certification for Public Service Loan Forgiveness form that Fed Loan Servicing
received from the AILA employee indicated that AILA provides "public education services". Our
research shows that AILA is a professional bar association primarily engaged in advocacy and
providing news and commentary on immigration issues to its members, and to the public in
general. For PSLF purposes, the Department considers "public education services" to be
services that provide educational enrichment or support directly to students or their families in a
school or a schooHike setting. Because AILA's educational activities are directed primarily to its
members and to the public in general, not to students or families, and are not provided in a
school or school-like setting, AILA does not provide public education for the purposes of the
PSLF Program.
We also reconsidered whether AILA provides public interest law services. For purposes of the
PSLF Program, "public interest law" is defined in 34 CFR 685.219(b) as "legal services
provided by a public service organization that are funded in whole or in part by a local, State,
Federal, or Tribal government." After further review, we determined that employees of AILA do
not provide public interest law services. Rather, such services are provided by AILA's member
attorneys. AILA's "find a lawyer" site at www.ailalawyer.com specifically states that AILA and
ailalawyer.com offer "no legal advice, recommendations, mediation, or counseling under any
circumstance," but merely assist individuals in finding an attorney.
Based on our more thorough review of AILA's status, and notwithstanding the informal
information we provided in 2012, we have determined that AILA is not a qualifying employer for
PSLF purposes. We regret any confusion that may have been caused by our earlier opinion,
but we must comply with all relevant statutory and regulatory requirements for the PSLF
Program.
If you have further questions concerning our determination of AJLA's status or the PSLF
Program, please contact Ian Foss of my staff, at ian.foss@ed.gov or 202-377-3681.
From: Foss Ian

To; Kimberly A Myers
Cc: Diane Freundel: Qhialastri Taneka
Subject: [external]Re: PSLF - American Bar Assoc1at1on
Date: 04/13/2016 08:42 AM
This is very helpful. Thank you!
One last request (for now).
Can we get a copy of one of the retraction letters (redacted) and also confirm that
the organization claimed to be a non-501 (c)(3) not-for-profit that was claiming to
provide public interest legal services. I realize that some may have come in as being
from the 501 (c)(3), even if it were ultimately determined that the borrower didn't
work there. So I'm asking about the ones that came in directly from the ABA.
On Apr 11, 2016, at 15:45, Kimberly A Myers <kmyers@pheaa.org> wrote:
Hi Ian!
Based on the query the Business Unit performed, there were 9 borrowers who were denied
outright and a total of 19 that received retraction letters. Of the 19 who received retractions
letter, 14 were picked up in this most recent query the Business Unit ran.
The longest timeframe from the date the borrower was originally approved to the date
retracted was 45 months. However, one thing to note for that particular borrower, the
Business Unit only retracted about 10 months of employment (from 8/2011 to 5/2012).
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
F181~1 "'Foss, Ian"' <lan.Foss@ed.gov>

I.:., "'Kimberly A Myers"' <kmyer5@pt1eaa.org>
Cc Diane Freundel <dfreunde@pheaa orq>. "Chialastri, Taneka"< Taneka.Ch1ala5jri@ed gov>
llc<e 04/08/2016 02.56 PM
S11h1ort [external]RE: RE: PSLF - American Bar Association
Cm you g\ 1R -nP a c:ensP of ho11"-nanv boe'O\Ners rPce\ 1nJ ., retr,,ct1011 rRgarrJ111gthe A"lA and 10w
rwnv 0
ece1ved oul11ghl den1Jls' A so, for those elrJclecl, how long Jfle
0 0
lhe a::ivoval did l·1e
rPt'<Kt101 go out ifo' the borro\liPr for 11"horn 1t was t1R ongPst)'
From: Kimberly A Myers [mailto:kmyers@pheaa.org]

Sent: Friday, April 08, 2016 2:12 PM
To: Foss, Ian

Cc: Diane Freundel; Chialastri, Taneka
Subject: Re: RE: PSLF- American Bar Association
Hi Ian! Outside of the employers Taneka listed below I don't believe we had forwarded any
other "Bar" or "Bar Associations" for review. Although we didn't escalate the employer, I
know you also initially made a determination on the American Immigration Lawyers
Association (which Jeff Baker also drafted a letter to the borrower that Taneka shared with
us).
I know in the beginning we were struggling with associations in general and specifically
organizations that would qualify under the "public interest legal services" category. At one
point, I know we had talked through it over the phone, which gave us a clearer
understanding of this category. Once we grasped what organization would/would not
qualify under this category, we internally made the decisions and only escalated to you the
ones we were on the fence about.
In regards to the American Bar Association, we made the decision internally that they do
not qualify and provided this guidance to the Business Unit. As we received ECFs from
borrowers employed by the American Bar Association, we were denying.
I know in some instances there were borrowers who were certified as working in a
qualifying arm of the American Bar Association (e.g. American Bar Association Fund for
Justice and Education under the EIN 36-6110299). If we had a reason to question it, we
would request the borrower's W-2 to confirm who actually paid the borrower. In most
instances, the borrower turned out to be employed by the American Bar Association directly
under the EIN 36-0723150. In light of your decision on ACLU, we now have reason to
question this further.
We were recently escalated an account for the American Bar Association where the
previous approval had not been retracted. As a result, the Business Unit ran a query to
identify and clean up those borrowers who may have been approved under the American
Bar Association in the past who should not have been. This is most likely where the
retraction of the previous approval came from.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
I"-""' "Chialastri, Taneka" <eTaneka.Ch1ala5tri@ed.gov>

To "Foss, Ian'· <lan.Foss@ed gov>, Diane Freundel <dfre11nde@pheaa.org>,"'Kimberly A Myers··•
<kmyers@pheaa.org >
D:,·c- 04/08/201612.02 PM
~;ui.Jiecl [external]RE: PSLF -American Bar Association
I dlri't ,how c1°·,v1li·11g

on rccucd fur tile 1\rncr"c,rn 3c1rA,,ucic1l10°·1.I U11lyh,1vc Jucurric ·,t,1t1un of
0
decisio~,s ·nade regardhg the King Cow,tv '.);n 1\ssoc :itio~,, 8ar Association ot San f-'ancisco, State
8,1r of W1,co ·,s1°·,,,1nd l"HCD1,tr1ll of Culurnb1c1 Bcir
0
From: Foss, Ian

Sent: Friday, April 08, 2016 11 :55 AM
To: Chialastri, Taneka; Diane Freundel; 'Kimberly A Myers'
Subject: PSLF - American Bar Association
Hello all,
Can you summarize for me what we've done regarding PSLF and the American Bar Association? We
just got a letter saying we approved them and then retracted it several years later. I'm not finding
record that I worked on it personally, but that doesn't mean its so.
Thanks,
lac
This message contains privileged and confidential information intended for the
above addressees only. If you receive this message in error please delete or
destroy this message and/or attachments.
The sender of this message will fully cooperate in the civil and criminal
prosecution of any individual engaging in the unauthorized use of this message.
Code:PHEAA
From: James J Jarecki

To; ,Jason
Swartley
Cc: RobertG Cameron;
CoreyDetar
Subject: PSLF - American Bar Assoc1at1on
Date: 03/30/2017 08:52 AM
JLS:
I received this email chain from Dan, which includes mostly an exchange b/w Kim
Myers and various people with DOE. I call your attention to Kim's email to DOE on
April 8, 2016, at 2:12 pm, which seems to suggest that FLS made the decision that
the ABA did not qualify.
I cannot be sure, based on this chain, whether FSA had any initial input into that
decision.
James J. Jarecki, Esq.

Associate Chief Counsel
AES/PHEAALegal & Compliance Services
1200 N. 7th Street
Harrisburg, PA 17102
telephone# (717) 720-1568
fax# (717) 720-3911
----- Forwarded by James J Jarecki/AES on 03/30/2017 08:42 AM -
Fro Ill Daniel Weigle/PHEAA

fo James J Jarecki/AES@PHEAA
[)ate· 03/29/2017 04:33 PM
S.JbJeCt Fw: [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Here's the history that I was provided. I did not talk to Kim Myers directly. We
should circle back with her and get the history, but I believe it's all contained in the
emails.
Thanks,
Dan
----- Forwarded by Daniel Weigle/PHEAA on 03/29/2017 04:29 PM -
lrom: Lauren M. Swett/PHEAA

fo Daniel Weigle/PHEAA@pheaa
[)ate· 03/29/2017 03:44 PM
S"ibJCCt: Fw: [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Per our discussion

...
Kim has said that, knowing what we know now, we should not have
approved the employment: however, at the time, based on decisions
made by FSA on other bar associations, we used the guidance we were
given at the time and approved. Of course, this particular employer was
not escalated to FSA.
Lauren M. Swett
Federal Contract Manager
Pennsylvania Higher Education Assistance Agency (PHEAA)
1200 N. 7th Street, Harrisburg, PA 17102
lswett@pheaa.org I o: 717-720-3693 I m: 717-678-9676
Forwarded by Lauren M Swett/PHEAA on 03/29/2017 03:42 PM
Frolll Lauren M. SwetVPHEAA

To Fedloan PSLF/PHEAA@PHEAA
Cc: Kimberly A Myers/PHEAA@pheaa, Melissa L Shoemaker/AES@PHEAA
D:1te 10/24/2016 04:35 PM
S,Jbject Re: Fw: [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Perfect. Thanks Kim! As I mentioned, Cindy Battle gave some indication that there
would be an FSA CR issued related to our communications to borrowers in these and
other denial scenarios.
Lauren M. Swett
Federal Contract Manager
1200 N. 7th Street, Harrisburg, PA 17102
lswett@pheaa.org I o: 717-720-3693 I m: 717-649-6231
FedLoan PSLF---10/24/2016 10:53:55 AM---Hi Lauren! Per our discussion, this is

the emailI sentto FSAregarding
the retractions.
Youcan
lrom: Fedloan PSLF/PHEAA
To Lauren M. Swett/PHEAA@PHEAA, Melissa L Shoernaker/AES@PHEAA
Date 10/24/2016 10:53 AM
S"ibJCCt: Fw: [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Sent by Kimberly A Myers
Hi Lauren! Per our discussion, this is the email I sent to FSA regarding the
retractions. You can read through the back and forth if you are interested on how
this transpired. Let me know if you have any questions. Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
----- Forwarded by Kimberly A Myers/PHEAA on 10/24/2016 10:53 AM -
Frolll FedLoan P]LF/PHEAA

To l(b)(5) I (b)(5) I
Cc· "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde@pheaa.org>,
'"Fedloan PSLF"' <FedLoanPSLF@pheaa.org>, "Utz, Jon" <Jon.Utz@ed.gov>, "Tiongquico,
Rene" <Rene.Tiongquico@ed.gov>
[)ate· 10/18/2016 03:52 PM
S"ibJcct: Re: [external]RE: Re: Re: Re: Re: PSLF- American Bar Association
Hi Tankea! Again, I apologize for the delay. I wanted to ensure I provided you with
accurate details. Overall it appears the Business Unit retracted a total of 320
employers, with a breakdown as follows: 4 in 2012, 37 in 2013, 123 in 2014, 64 in
2015 and 92 in 2016. These numbers also include the employers that you are aware
of. I know the Business Unit performed some clean-ups (specifically in 2014 and
2016) to identify any employers who might have been approved in error.
Based on internal reviews (those outside of the employers we escalated to FSA), the
breakdown of retractions is as follows: 243 were deemed for-profit and 49 were
deemed not-for-profit but not providing a qualifying public service. There were some
other miscellaneous retractions (e.g. we retracted the approval to request additional
clarifying information due to conflicting information received via a later ECF,the
borrower was determined to be a volunteer, etc). Just to note, some of the
retractionswere due to the borrower providinginaccurateinformationon the initial
ECFwhich wasn't identified until he/she submitted a subsequent ECFwith conflicting
information.
Most of the retractionswere due to processorerror.
Please let me know if you have any questions. Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
l(bl(5I 1---10/17/2016 03:52:14 PM---Hi Kim, I just wanted to follow-up to

findoutif youwereableto findoutthe averagenumberof re
From· l(b)(5) I (b)(5)
To: "'Fedloan PSLF"''c.< l(b)(5) I
7 F,'e~d~L,=a~,P~S"LF-F@~p~h=e='aa.org>, (b)(5)
7 7
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <'cdrr-fr=e,=c~dce@=ph~e=aa
. oc=g~>.
"Utz, Jon" <Jon.Utz@ed.gov>, "Tiongquico, Rene" <Rene.Tiongquico@ed.gov>
Date: 10/17/2016 03:52 PM
S.JbJect [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
I Just wanted to follow-up to find out if you v,'P.rea hie to find out thP. ,lVP.r,lgP.
number of retractions that arc issued by Pl 1[1\/\.
Thar1ks,
Taneka
From: Chialastri, Taneka

Sent: Wednesday, October 12, 2016 11 :22 AM
To: 'Fedloan PSLF'; l(bl(5I I
Cc: Battle, Cynthia; Diane Freundel; Utz, Jon; Tiongquico, Rene
Subject: RE: Re: Re: Re: Re: PSLF- American Bar Association
111l(im,
Do you have an idea ol lhe average number of relraclions Lhal are issued by PHEAA
on ,1 yearly has1s? Add1tion;illy, would you know about hov,/ m;iny of those
retractions arc for employers who were non profit that we determined did not
provide a qualifying service and those who PHEAAjust determined were for-profit)
Tenlalively, I would say lhal we would like Lo be aware of all relracl1on'>, especially
in the 1nst;rnre where the retraction 1s going out years ,1fter the borrower's
employment 1s approved, and be able to review the letters before going out to
borrowers We'll wait to hear about the volume that you anticipate we would need
Lo review before making any decisions.
Thanks,
Taneka
Hi Taneka! Historically, if an employer retraction is because of

changing guidance, etc, we will escalate those to you before taking
action. However, if we discover internally that an employer was
approved in error by a processor (e.g. employer was accidentally
approved but it was always for-profit), we will take care of those
internally and not escalate. Based on your wording below, would you
now expect these situations to be routed to you first before we take
action, even though we know the approval an obvious error?
We can definitely forward the retraction letter to you before they are
sent to the borrower. Just for our knowledge, would you expect to have
a quick turnaroundin reviewingthese letters so that we can get them

out to the borrower as soon as possible?
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
f-10111 l{b)(5)
Io Fed Loan PSLF <FedLoanPSLF@pheaa.org>
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde@pheaa org>, "Utz, Jon"
<Jon.Utz@ed.gov>, "Tiongquico, Rene" <Rene.T1ongciuico@ed.gov>, "Chialastri, Taneka"
<Taneka. Ch ialastri@ed.gov>
Date 10112/201610:11 AM
Sub1ect [external]Re: Re: Re: Re: PSLF American Bar Association
Hi Kim,
Thanks again for pulling information regarding the American Bar Association.
I believe this already occurs, but wanted to confirm if all retractions of

qualifying employment for PSLFare routed to FSAfor review? If not, we would
like to request that in the rare instance PHEAAbelieves we need to retract an
approval FSAis notified through this mailbox so that we may review the
circumstances of the retraction.
Moving forward, we would also like to review a copy of the retraction letter(s)
before they are sent to the borrower regarding their qualifying employment.
On this end, we are in the early stages of discussing ways that FSAcan improve
StudentAid.gov and other outlets to increase transparency regarding the PSLF
process and eligiblity for non-501(c)(3) employers providing qualifying public
services. I'll make sure to provide PHEAAwith an update as more information is
available.
If you have any concerns or questions please let me know.
Kind Regards,
Taneka
From:Kimberly A Myers <kmyers@pheaa.org> on behalf of Fed Loan PSLF

<FedLoanPSLF@pheaa.org>
Sent: Friday, October 7, 2016 1·52 PM
To: i(b1(51 I
Cc: Battle, Cynthia; Diane Freundel; Fed Loan PSLF; Utz, Jon; Tiongquico, Rene;
Chialastri, Taneka
Subject: Re: Re: Re: Re: PSLF- American Bar Association
Hi Taneka! You are correct in you assumptionfor the retractiontab.

The processed date is the date it was approved. Essentially it all occurs
in one step (the ECF is processed as an approval).
With the retraction letters, we had previously advised that the Business
Unit that they need to include more detail. Previously it was very
generic (it just basically stated that the employer was retracted, but
didn't give much explanation as to why). It has gotten better, but we can
certainly work more with the Business Unit to "beef" up the denial
letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From
To Fedloan PSLF <FedLoanPSLF@pheaa org>

Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>. Diane Freundel <dfreunde@pheaa.org>,
"Tiongquico, Rene" <Rene.Tiongquico@ed.gov>. "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>.
"Utz, Jon" <Jon Utz@ed.gov>, l{b)(5) I<Publicservice@ed.gov>
Date 101071201601 :47 PM
Sul1iecI [external]Re: Re: Re: PSLF - American Bar Association
Hi Kim,
We really appreciate the quick turnaround on this information.
Quick question for the retraction tab - Is the processed column date the date
that the borrower's ECFwas approved?
In regards to the retraction letter - I know we previously discussed PHEAA

providing more detail in the retraction letter and I recall the Business Unit
making a few changes; however, I think we may need to revisit the way the
retraction letters are drafted to ensure that we are being as transparent as
possible to borrowers who are being informed that a previously qualified
employer is no longer eligible. I'm going through emails and noticed the
retraction letter is similar for borrowers employed with Students First so
wanted to make sure that we make every effort to make sure borrowers are
informed.
Thank you,
Taneka
From: Kimberly A Myers <kmyers@pheaa.org> on behalf of FedLoan PSLF

<FedloanPSLF@pheaa.org>
Sent: Friday, October 7, 2016 12:26:29 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; FedLoan PSLF;Tiongquico, Rene; Chialastri,
Taneka
Subject: Re: Re: Re· PSLF- American Bar Association
Hi Taneka! I was able to pull together the information you requested

(no pressure for a mid-Friday) : )
I attached a spreadsheet which provides the borrowers whose ECFs

were approved then retracted, as well as the borrowers whose ECFs
were denied outright. The spreadsheet has two tabs with each cohort of
borrower.
For the borrower whose approval was retracted after 45 months, I

included the letters we have on record. There is one system generated
denial letter, one system generated approval letter, and the manual
retraction letter. Just a head's up on the system generated denial
letter. His ECF was originally not complete, so the denial is for missing
information. He returned another, complete, ECF which is the one that
was approved.
If there is anything else you need, please do not hesitate to ask.

Password to follow. Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From l{b)(5) ljtb)(5)

le Kimberly A Myers <kmyers@pheaa.org>
Cc Diane Freundel <dfreunde@pheaa org>, "Chialastri, Taneka" <Taneka Ch1alastri@edgov>,
"Tiongquico, Rene" <Rene T1ongquico@ed.gov>. "Battle, Cynthia" <Cynthia Battle@ed gov>, FedLoan
PSLF <FedLoanPSLF@pheaa.org>, l(b)(5) I
~(b)(5l I
D,1te 10/07/2016 10:28 AM
Suhw:;t [external]Re: Re: PSLF - American Bar Association
Hi Kim,
Would you be able to provide detailed information on the borrowers whose

qualifying employment was was outright denied for the American Bar
Association as well as the borrowers who were originally approved and
received retractions to date.
If possible, we need a secure file listing the borrowers names, SSN, Employer
EIN, the date the ECFwas received, Processed, Approved, Denied, Retracted
,and Notes (if applicable). Additionally, we would also like to see a few
approval, denial and retraction letters for the borrower who had their approval
denied after 45 months.
My apologies for having to request this on a Friday but if your team can pull
this information as soon as possible we would appreciate it. Please let me know
if you have concerns.
Thanks,
Taneka
From: Kimberly A Myers <kmyers@pheaa.or~>

Sent: Wednesday, April 13, 2016 8:34:28 AM
To: Foss, Ian
Subject: Re: Re: PSLF- American Bar Association
Hi Ian! Attached is a redacted copy of the ECF and corresponding

retraction letter to the borrower. Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
From "Foss, Ian" <lan.Foss@ed.gov>
Tr: Kimberly A Myers <kmyers@pheaa.org>
Cc Diane Freundel <dfreunde@pheaa.org>, "Chialastri, Taneka'" <Taneka.Chia1as1ri@ed.gov>
D,1te 04/13/2016 08:42 AM
Suhw:;t [external]Re: PSLF - American Bar Association
Can we get a copy of one of the retraction letters (redacted) and also confirm
that the organization claimed to be a non-501(c)(3) not-for-profit that was
claiming to provide public interest legal services. I realize that some may have
come in as being from the 501(c)(3), even if it were ultimately determined that
the borrower didn't work there. So I'm asking about the ones that came in
directly from the ABA.
Hi Ian!
Based on the query the Business Unit performed, there were 9

borrowers who were denied outright and a total of 19 that received
retraction letters. Of the 19 who received retractions letter, 14 were
picked up in this most recent query the Business Unit ran.
The longest timeframe from the date the borrower was originally
approved to the date retracted was 45 months. However, one thing to
note for that particular borrower, the Business Unit only retracted about
10 months of employment (from 8/2011 to 5/2012).
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
To '"Kimberly A Myers"' <kmyers@pheaa org>
Cc Diane Freundel <dtreunde@pheaa.org>, "Chialastri, Taneka'" <Taneka.Chialastri@ed.gov>
Date 04/08/2016 02:56 PM
Suhw:;t [external]RE: RE: PSLF American Bar Association
This is super helpful Thanks, Kim
Can you give me a sense of how many borrowers received a retraction

regarding the ABA and how many received outright denials? Also, for those
retracted, how long after the approval did the retraction go out (for the
borrower for whom it was the longest)?

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we

had forwarded any other "Bar"or "Bar Associations"for review.
Although we didn't escalate the employer, I know you also initially made
a determinationon the American ImmigrationLawyers Association
(which Jeff Baker also drafted a letter to the borrower that Taneka
shared with us).
I know in the beginningwe were strugglingwith associationsin general

and specifically organizations that would qualify under the "public
interest legal services" category. At one point, I know we had talked
through it over the phone, which gave us a clearer understanding of this
category. Once we grasped what organization would/would not qualify
under this category, we internally made the decisions and only
escalated to you the ones we were on the fence about.
In regards to the American Bar Association, we made the decision

internally that they do not qualify and provided this guidance to the
Business Unit. As we received ECFs from borrowers employed by the
AmericanBar Association,we were denying.
I know in some instancesthere were borrowerswho were certifiedas

working in a qualifying arm of the American Bar Association (e.g.
American Bar Association Fund for Justice and Education under the EIN
36-6110299). If we had a reason to question it, we would request the
borrower's W-2 to confirm who actually paid the borrower. In most
instances, the borrower turned out to be employed by the American Bar
Association directly under the EIN 36-0723150. In light of your decision
on ACLU, we now have reason to question this further.
We were recently escalated an account for the American Bar

Association where the previous approval had not been retracted. As a
result, the Business Unit ran a query to identify and clean up those
borrowerswho may have been approved under the American Bar
Association in the past who should not have been. This is most likely
where the retraction of the previous approval came from.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>

Tr: "Foss, Ian" <Ian Foss@ed.gov>. Diane Freundel <dfreunde@pheaa orq>, "'Kimberly A Myers"'
<kmyers@pheaa org>
D,1te 04/08/201612:02 PM
[external]RE: PSLF - American Bar Association
Hi Ian,
I don't show anything on record for the American Bar Association I only have
documentation of decisions made regarding the King County Bar Association,
Bar Association of San Francisco, State Bar of Wisconsin, and the District of
Columbia Bar.
Thanks,
Taneka
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLFand the American
Bar Association? We just got a letter saying we approved them and then
retracted it several years later. I'm not finding record that I worked on it
personally, but that doesn't mean its so.
Thanks,
Ian
above addressees only. If you receive this message in eITor please delete or
Code:PHEAA
From: Foss Ian

To: FedLoan PSLF; Chialastri Taneka
Cc: Odom Christian; Battle Cynthia: Diane Fre11ndel:'Lauren M. Swett·:~kb~J(~5)~~
Subject: [external]RE: PSLF Employer Escalation Meeting M1nutes_01302017
Date: 02/03/2017 01 :48 PM
Th;rnks ;i lot, Kimi

b)(5)
Basically, we have three documents:
• The initial PSLFCR, which incorporated the 2011 ECF processing guide by reference This
guide required you lo escalale all nor1-50l(c)(:)) non-profits lo us unle:,:,,
• The email from me in 2012, which, though ambiguous in hindsight, told you that, at a
minimum, you didn'L need lo escalale organi,:alior1s Lhal were nol govermnenlal or SOl(c)
(3 )s 1fyou rnuld determine th;it they were for-profit org;in1z,1t1ons
• The 2012 "st;indard1zed review process", which does 1nrnrpor;ite the gu1d;ince th;it I sent 1n
2012 related to for profits, but doesn't address under what circumstances things would be
escalated to us
b)(5)
From: Kimberly A Myers [mailto:kmyers@pheaa.org] On Behalf Of Fedloan PSLF

Sent: Friday, February 03, 2017 12:37 PM
To: Chialastri, Taneka
Cc: Odom, Christian; Battle, Cynthia; Diane Freundel; 'Fedloan PSLF'; Foss, Ian; 'Lauren M. Swett';
!(b)(5) I
Subject: Re: PSLF Employer Escalation Meeting Minutes_01302017
Hi Taneka! Realized I forgot the attachment.
Thanks I
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
51__
cl(bL)(~ 0 I:From
Tuesday, February 28, 2012 7.45 AM :Sent
Fedloan PSLF:To
--~I
Johnson, Debbe cl(bL)(~5L) Foss, Ian; Ninemire, Sandra, Sipple-Asher, Bessie :Cc
RE Columbia Physical Therapy PS:Subject
and therefore does not qualify. You I agree that this 1sa for-profit entity
it's If .may stop escalating cases where the employer is clearly for-profit
and a close case, or you're not sure that it's a clear case, then go ahead
.continue escalating it
-----Original Message-----<
From· Diane Freundel <
On Behalf Of I ma1lto:dfreunde(a!aessuccess.org I
Fedloan PSLF<
,Sent. Monday<
February 27, 2012 8:07 PM
To:l(b)(5) I<
Subject: Columbia Physical<
Therapy PS
<
<
Please see the attached ECFand information from the ,Hi <
WA Corporations
Please let us know .This entity 1sfor profit .D1v1s1on
<
if you want to
continue to see entities that checked box c that are for<
Password profit
!Thanks .to follow<
<
See attached file: Columbia)<
(Physical Therapy_ Hodgson.zip
<
Diane Freundel <
Compliance Services<
<
720-1267 (717)
fax- (717) 720-3911 <
dfreunde@pheaa.org <
<
<
This message contains privileged and confidential<

information intended for
If you receive this .the above addressees only<
message 1nerror please
delete or destroy this message and/or<
.attachments
<
The sender of this message will fully cooperate 1nthe<
civil and crirrnnal

prosecution of any individual engaging in the<
unauthorized use of this
.message<
<
<
This message contains privileged and confidential information intended for the above
addressees only. If you receive this message in error please delete or destroy this message
and/or attachments.
The sender of this message will fully cooperate in the civil and criminal prosecution of any
individual engaging in the unauthorized use of this message.
Code:PHEAA
I r0I11 Fedloan PSLF/PHEAA

I c• "Chialastri. Taneka" <Taneka.Chialastri@ed.gov>
"Odom, Christian'· <Christian.Odom@ed.gov>. "Battle, Cynthia"' <Cynthia.Battle@ed.gov>. Diane Freundel
<dfreunde@pheaa.org>, '"FedLoan PSLF"" <FedLoanPSLF@pheaa.org>, "Foss, Ian"' <lan.Foss@ed.gov>. '""Lauren M. Swelt"'
<lswett@pheaa.org>, l{bj(5) Il{bj(5)
Dc1l~ 02/03/2017 12:34 PM
s,.,1_~,
t Re: [external)(external]PSLF Employer Escalation Meeting Minutes_01 302017
Srnt hv Kimberly A Myers
Hi Tanekal
We recall both the discussion with Ian and receiving the ECF Processing Protocol in December 2011, that
was shared with the Business Unit to be used when processing ECFs.
b)(5)
I think Diane said Ian also had some questions about the ABA timeline. I had sent him an email on
4/8/2016 with a summary of what transpired with the ABA. I can resend if needed.
In regards to your other requests:
--- I hope to be able to provide you, by COB today, the information on the 501 (c)(4) organizations that you
requested.
--- We currently have 2 staff who devote approximately 25 hours total a week on ECF escalations. On
average, we receive about 340 escalations per month.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From "Chralastri, Taneka" <Taneka Chralastrr@ed gov>

Tc- "'Kimberly A Myers"' <kmyers@pheaa.org>. Drane Freundel <dfreunde@pheaa.org>. '"Lauren M. Swett"' <lswett@pheaa.org>,
'"Fedloan PSLF"' <FedLoanPSLF@pheaa.org;,
'.~:· "Battle, Cynthia" <Cynthia.Battle@ed.gov>, "Foss, Ian·' <lan.Foss@ed.gov>, '"Odom, Christian·' <Christian.Odom@ed.gov>,
!(b)(5) I!(b)(5) I"Chralastri. Taneka" <Taneka.Ch1alastrr@ed.gov>
Date 02/01/2017 04:28 PM
SL,,;_ecl [external][external]PSLF Employer Escalation Meeting Minutes_01302017
11l(1rn,
Thanks again to you a·1cl the resl of the learn al =eci_oan for rneet1·1g v/l·1 FSA to discuss the [·n::ilover [scalal·o·1
process. Allached are rneet1·1g rn1nules, a 2012 email f orn Ian lo =eciloan regcird·ng L·1eernploy·e escalation
0 0
process cir1dJ ver,1011 of tile ECF Proce,,1 ·,g :>cotoco from Dec 2011 thJt ,ve weT c1Uleto locc1lc 1r1ow cird11ve,
~or l··,c e1T1J11-l(b)(5) I
(b)(5)
Th;rnks,
Taneka
Taneka Chialastri I Management and Program Analyst, Bu,ine,s Operation, I Federal Student Ard
830 First Street N[, Washington, DC 20202
Office: 202-377-4390 I Cell 202-256-7842 I taneka chialastri(a!ed gov
-- 0000+ Feb 2017 19:34:57 on Wed. 1 ~(b~l(~5I

______ ~ Message from l(b)(5J ~----
"Chialastri, Taneka''
<Taneka.Chialastri@ed.gov> :To
Fw: Columbia Physical Therapy PS :Subject
From: Fedloan PSLF

Sent By: Kimberly A Myers
To; ~: ChialastriTaneka
Cc: Odom Christian: Battle Cynthia; Diane Freundel: Fedloan PSLF; 'Lauren M Swett' 1-lb-)(5-1_~
Subject: Re: [external]RE: PSLF Employer Escalation Meeting Minutes_01302017
Date: 02/03/2017 03:11 PM
Ian - While the 'Standardized Review Process' didn't go into great detail regarding
the private not-for-profit scenario, the document states "Google for website ... If exact
match found and website clearly indicates qualifying not-for-profit status, approve".
This processwas a high overview and more detailed procedureswere utilized
internally. We agree, this is poorly written, but the intent of "qualifying" not-for-
profit status meant it had to provide a qualifying public service.
We have always reviewed a not-for-profit employer (non 501 (c)(3)) for qualifying
publicservice. As you know, there is no clear-cut review processto go though;
however, over the course of Compliances involvement and through developing our
researchskills,we created a formalizedprocedurewe utilizewhile reviewingthe
escalated employers.
Based on our documentation, and from what we can remember, we had escalated all
private not-for-profits to FSA. We also escalated any governmental or 501 (c)(3)
employers we were unsure of. Based on your 2/28/12 email, you are correct, we
interpretedyour email to mean we could make decisionsinternallyunlessit was
unclear,
Taneka - In regards to your request for 501 (c)(4) employer data, we noted there
were a total of 149 escalated to Compliance. Of these, 15 were escalated to FSA (7
approved and 8 denied. Of the remaining 134, we approved 30, denied 95, and
returned 9 to the Business Unit to obtain additional information. Please note, these
numbersare based on the informationwe inputted into our spreadsheet. Therefore,
if we didn't specifically note the employer was 501 (c)(4), they would not appear in
our query.
Please let us know if you need any additional information. Have a great weekend!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
"Foss,Ian" ---02/03/201701:48:11PM---Thanks
a lot, Kim!Question:the
documentyou attached seemsto cover only one componentof the revi
To· Fedloan PSLF<FedLoanPSLF@pheaa.org>, "Chialastri, Taneka"
<Taneka. Chialastri@ed.gov>
Cc "Odom, Christian" <Christian.Odom@ed.gov>, "Battle, Cynthia"
<Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde heaa.or > '"Lauren
M. Swett"' <lswett@pheaa.org>, l(b)(5) (b)(5) I
D:1te 02/03/2017 01 :48 PM ~-----~
SJbject· [external]RE: PSLFEmployer Escalation Meeting
Minutes_01302017
Thanks a lot, l(im!

b)(5)
Basically, we have lhree docurnenb:
• The initial PSLFCR, which incorµoraled lhe 2Ull ECF processing guide
hy reference. This guide required you to escalate all non-501(c)(3) non-
profits to us unless.
• The email from me In 2012, which, though ambiguous in hindsight,
told you that, at a minimum, you didn't need to escalate organizations that
were not governmental or 501(c)(3)s if you could determine that they were
for-profit orgar11,:alIons.
• The 2012 "standardized review process", which does incorporate the
guidar1ce lhal I senl ir12Ul2 related lo for-µrof1Ls, bul doesn'L addre:,:, under
what circumstances things would be escalated to us.
b)(5)
From: Kimberly A Myers [mailto:kmyers@pheaa.org] On Behalf 01

Fedloan PSLF
Cc: Odom, Christian; Battle, Cynthia; Diane Freundel; 'Fedloan PSLF';
Foss, Ian; 'Lauren M. Swett'; l(bl(5I I
Subject: Re: PSLF Employer Escalation Meeting Minutes_01302017
Hi Taneka! Realized I forgot the attachment.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Frrnn FedLoan PSLFIPHEAA

Io "Chialastri. Taneka" <Taneka.Chialastri@ed.gov>
Cc "Odom, Christian" <Christian.Odom@ed.gov>. "Battle, Cynthia" <Cynthia.Battle@ed.gov>,
Diane Freundel <dfreunde@pheaa.org>, '"Fedloan PSLF"' <FedLoanPSLF@pheaa.org>, "Foss, Ian"
dan.Foss@ed.gov>, "'Lauren M. Swett"' <lswett@pheaa.org>,~kb~J(~5)
__ ,ol ~b~5~----~
Date 02103/201712:34 PM
Sub1oct Re: [external][external]PSLF Employer Escalation Meeting Minutes_01302017
Hi Taneka!
We recall both the discussion with Ian and receiving the ECF
Processing Protocol in December 2011, that was shared with the
Business Unit to be used when processing ECFs.
Our interpretation of Ian's email was that we should internally deny any
ECF where we could conclusively determine for-profit status, regardless
of which box was checked on the ECF. In addition, through subsequent
discussionswith Ian, it was also our understandingthat if we were
unable to determine eligibility,the onus of provingan organization's
eligibility is on the borrower and employer to provide the necessary
information. Due to questionssurroundingthe escalation process,we
internally created a 'Standardized Review Process'. We vetted the
document through FSA. We are currently following the process outlined
in this document, with some modifications. Since the date this
documentwas created, we found additionalresourceswe use to further
determine qualifying status. We attached the most recent version we
have on file (from April 2012).
Also, I understand Diane had a brief discussion with Ian this morning
about the ABA and AILA. As we recall, we first escalated the AILA in
May 2014 when we received an ECF for the organization. In June 2014
Ian replied that he agreed with our assessment that the organization did
not qualify. Subsequently in December 2014, Ian sent us the letter
from Jeff Baker to Ms.~ advising her that the Department was
retracting its previous assessment of the AILA's eligibility. That was the
first indication we had that the Department had determined the AILA
was eligible.
I think Diane said Ian also had some questions about the ABA timeline.
I had sent him an email on 4/8/2016 with a summary of what transpired
with the ABA. I can resend if needed.
--- I hope to be able to provide you, by COB today, the information on

the 501 (c)(4) organizations that you requested.
--- We currently have 2 staff who devote approximately 25 hours total a

week on ECF escalations. On average, we receive about 340
escalations per month.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From "Chialastri. Taneka" <Taneka.Chialastri@ed.gov>

Io '"Kimberly A Myers"' <kmyers@pheaa.org>, Diane Freundel <dfreunde@pheaa.org>, '"Lauren
M. Swett"' <lswett@pheaa.org>, "'Fedloan PSLF"' <FedLoanPSLF@pheaa.org>
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>. "Foss. Ian" <lan.Foss@ed.gov>, "Odom, Christian"
<Christian.Odom@ed.gov>, l{b)(5) I b 5 "Chialastri, Taneka"
<Taneka. Ch ialastri@ed.gov>
D,1te 02/01/2017 04:28 PM
[external][external]PSLF Employer Escalation Meeting Minutes_01302017
Hi Kim,
Thanks again to you and the rest of the team at FedLoan for meeting with FSA
to discuss the Employer Escalation process Attached are meeting minutes, a
2012 email from Ian to FedLoan regarding the employer escalation process,
and a version of the ECFProcessing Protocol from Dec. 2011 that we were able
to locate in our archives For the email - could you tell us if FedLoan
interpreted the email guidance to mean that Compliance didn't need to
escalate PSLFdeterminations that were for-profit {only), or if Compliance didn't
need to escalate any organizations to FSAif they were confident in their
decision? For the protocol - could FedLoan confirm if this document was
provided to the business unit to use as a rubric for reviewing employer
escalations?
After the meeting, we also realized that there were a few outstanding
questions that we still need clarification on If you could provide responses as
soon as possible to the two questions (below) it would be much appreciated
• Would FedLoan be able to provide the total number of 501(c){4)

organizations that have come through Compliance for review and the
breakdown of approvals, denials, and accounts escalated to FSA?
• Would FedLoan be able to tell us how many full-time staff in Compliance
are working on escalations and what the average monthly volume is?
Please let me know if there are any questions regarding this email or edits to
the meeting minutes.
Thanks,
Taneka
Taneka Chialastri I Management and Program Analyst, Business Operations I

Federal Student Aid
830 First Street NE, Washington, DC 20202
Office: 202-377-4390 I Cell 202-256-7842 I taneka.chialastri@ed.gov
Message from 5_I__

L!(b_l( ~I 5_I___
L(b_l( ~~~=~ on Wed, 1 -----
----- Feb 2017 19:34:57 +0000
To: <Chialastri.Taneka"<Taneka.Chialastri@ed.gov"
Subject: Fw: Columbia Physical Therapy PS
From: cl(b~l(~51
__ ~
Sent: Tuesday, February 28, 2012 7:45 AM
To: Fedloan PSLF
Cc: l(bJ(5J IFoss, Ian; Ninemire, Sandra; Sipple-Asher, Bessie: Johnson,
Debbe
Subject: RE: Columbia Physical Therapy PS
I agree that this is a for-profit entity and therefore does not qualify. You
may stop escalating cases where the employer is clearly for-profit. If it's
a close case, or you're not sure that it's a clear case, then go ahead and
.continue escalating it
-----Original Message-----<
From: Diane Freundel <
mailto:dfreunde@aessuccess.org l On Behalf Ofl
Fedloan PSLF<
,Sent: Monday<
February 27, 2012 8 07 PM
To i(b1(51 I<
SubJect: Columbia Physical<
Therapy PS
<
<
Hi. Please see the attached ECFand information from the<
WA Corporations
Division. This entity is for profit. Please let us know<
if you want to
continue to see entities that checked box c that are for<
profit. Password
!to follow. Thanks<
<
See attached file: Columbia)<
(Physical Therapy_Hodgson.zip
<
Diane Freundel <
Compliance Services<
<
720-3267 (717)
fax- (717) 720-3911 <
dfreunde@pheaa.org <
<
----------------------------------------------------------
<
This message contains privileged and confidential<

the above add ressees only. If you receive this <
message in error please
delete or destroy this message and/or<
.attachments
<
The sender of this message will fully cooperate in the<
civil and criminal
prosecution of any individual engaging in the<
.message<
<
----------------------------------------------------------
<
--------------------
Code:PHEAA
PSLF Employer Escalation Meeting

January 30, 2017
Attendees:
FSA: Cindy Battle, Taneka Chialastri, Ian Foss, Christian Odom
PHEAA/Fedloan Servicing: Diane Freundel, Kim Myers, Lauren Swett, Joyce Zaleski, Bob Cameron
Meeting Overview:
Discussion of Fed Loan Servicing's internal Employer Escalation Process
General Discussion:
1. Fed Loan Servicing provided clarification on the Business Unit's process of reviewing employers
for PSLFeligibility and the circumstances that warrant an escalation to the Compliance Unit.
From Fedloan:
• The Business Unit (BU) will review all new ECFemployers for PSLFeligibility to determine
501(c)(3) or governmental status. These statuses are generally determined by the BU
visiting the Master Business File, IRSService Check, identifying the email address or
website as governmental, or conducting an EIN Search.
• The Business Unit will approve previously reviewed (and approved) escalations for
employers where the Compliance Unit had to make the determination of eligibility if the
approval occurred within 1 year time frame
The Business Unit will escalate an employer to the Compliance Unit in all instances where:
• The BU is unable to determine 501(c)(3) or governmental status; or

• The previously approved escalation has an approved status beyond 1 year (re-review); or
• If a borrower/employer is disputing a denial of qualifying employment
The Compliance Unit will escalate employers to FSAin certain instances where:
• It is difficult to determine whether an organization provides a qualifying service; or

• a borrower/employer is disputing a denial and the reason is not for an employer who has
previously been determined to be for profit or for borrower error; or
• A decision is being retracted (all cases as of November 2016)
Page 1 of 2
2. Discussion regarding guidance provided to FedLoan on escalation process.

• There is discussion among the group regarding the actual escalation process that
occurred in 2012 and if all escalated cases were to be provided to FSAand when the
process has changed.
Guidance
o 5_1__
After the meeting FSA located an email dated Feb. 28, 2012, from ~l(b_l( ~
mailbox to FedLoan stating that FedLoan could stop escalating cases where the
employer is clearly for-profit.
o PSLFRequirement 202.02 states that FedLoan will only escalate issues where a
decision can not be determined; however
o ECFValidation Protocol from Dec. 2011 (see attached) states that all non
501(c)(3) will be escalated to department.
3. Operational processing notes

• When decisions are determined Compliance will send the file back to the BU for letter
generation and processing.
• There is no internal trigger on all impacted borrower accounts when a retraction
occurs; however the BU will periodically run queries on employers who have had
decisions retracted to reconcile borrower accounts. Additionally, the Compliance
office will remind the BU to check for other borrowers when changes in an employer's
approval or denial status occur.
• The Compliance Office maintains a comprehensive employer escalation list. The list
may contain duplicates is ECFare received under differing names or EIN #'s. Dates of
review are also listed as the Compliance office needs to review employers with
decisions that are older than a year.
o FedLoan estimated that there are over 14,000 employers that have been
escalated since 2012
4. FedLoan and FSAdiscussions on employer escalation process moving forward

• FSA is requesting that FedLoan provide comprehensive list of employers that have
been escalated to FedLoan Compliance
• FedLoan will continue forwarding all retraction cases to FSA
Page 2 of 2
Public Service Loan Forgiveness

Standard ECF Review Process
A. Government Employer Qualification Review

1. Google for organization website
2. If domain is .gov, or .mil, approve
3. If it is a public school, approve 1
4. If a military branch, approve (Army, Navy, Air Force, Marines, Coast Guard, state national
guard)
5. If domain is not .gov, or .mil, search state and/or local government websites
6. Check EMMA (Electronic Municipal Market Access) database- if listed, approve
7. Quasi-government: Follow process above, then steps 1. - 3. under Private Not-for Profit
8. If not able to locate, deny
B. 501 (c)(3) Employer Qualification Review

1. Check IRS Publication 78: If listed, approve
2. If not in Pub 78, check IRS Business Master File: If listed and subsection code is 3, approve
3. Because religious entities may self-certify as a 501(c)(3), and therefore may not be listed on
IRS Pub. 78 or in IRS Business Master File even if qualified, all religious entities certifying as
a 501(c)(3) on the ECF should be approved unless clearly erroneous
4. If not found in either list, deny
C. Private Not-for-Profit Employer Qualification Review

1. Check SEC/EDGAR database: If found, deny as publically-traded for-profit business
2. Check state Corporation Bureau or Secretary of State database for the state of the employer
address on the ECF: If listed as NFP, accept, otherwise, deny
3. Google for website:
i. If no exact match, deny
ii. If exact match found and website clearly indicates qualifying not-for-profit status,
approve
D. Qualifying Employer Review/ "Second Look" Process

1. Request additional documentation of employer's qualifying NFP status. 2 Examples:
i. Documentation of NFP status from federal or state government or regulatory/ taxing
body (letter, reference to online database, etc.)
ii. Certificate of incorporation /charter
iii. Implementing legislation
2. Suggest requesting such documentation with submission of ECF to expedite review.
3. Deny if documentation is not provided or is not dispositive
E. Treatment of Incomplete ECF Data
1. Section 1: Borrower Information: Deny in all cases with following exceptions:

a. Missing Middle Initial
1 Public schools may have .org domains; .edu may be NFP or for-profit entities
< Financial data may be redacted.
b. Missing Prior Name

c. Missing Email
d. Missing (i) City and/or State or (ii) Zip Code AND address can be verified through data
provided (Street Address, City, State or Zip Code)
e. Missing Alternative Address
f. Missing Other Telephone
g. Telephone listed as NIA
h. Make borrower contact attempt to obtain required information prior to denial
2. Section 2: Borrower Certification: Deny if not both signed and dated by borrower

a. Item 1 (Entity Name, EIN, Address): Deny if any field is not complete
b. Item 2 (Borrower Employment Status): Deny if any field is not complete
c. Item 3 (Type of Public Service Organization): Deny 3
d. Make 1 attempt to contact employer to obtain required information prior to denial
4. Section 3: Employer Certification - Deny if any field is not completed on the ECF
a. Certifying official name, title and signature must be included;
b. Authority of Authorized Official will be deemed self-certifying unless except where the
borrower signs as the Authorized Official
c. Employer certification must be completed on the ECF
F. Treatment of Erroneous or Conflicting ECF Data
1. Section 1: Borrower Information

a. Name Discrepancy: Accept minor variations (e.g., Kim/Kym, Mike/Michael) or if NSLDS
matching criteria are met; deny for all other discrepancies
b. Address or Telephone: Accept; resolve discrepancies upon conversion
c. Email: Accept; resolve discrepancies upon conversion
d. SSN: Deny if SSN provided does not match NSLDS or servicing system
e. Make borrower contact attempt to obtain required information prior to denial
2. Section 2: Borrower Certification: See E.2, above.

a. Item 1 (Entity Name, EIN, address)
i. Deny if name and EIN do not match
ii. Accept if Entity Name and EIN are verified without regard to address
b. Item 2 (Borrower's Employment Status): Deny if hours listed do not meet status minimum
(e.g., FT and 20 hrs/wk); otherwise, accept based on status checked (e.g., PT and 35 hrs/wk)
c. Item 3 (Type of Public Service Org.): Deny4
d. Make 1 attempt to contact employer to resolve conflict prior to denial
G. Miscellaneous
1. Religious Employment - Always approve based on hours certified on revised ECF if certified by
employer; we will not make value judgments as to the nature of the individual's employment
2. Alternative Employer Certification Documentation - Suggest that all certification information be

provided on ECF.
a. When incomplete alternative documentation is submitted, FSA suggests including a letter to
the employer with the rejection notice which directs them to the employer section of Q&As
3Failure to certify NFP status nullifies the certification

4
Failure to certify NFP status nullifies the certification. We will make efforts to tailor denial letters, e.g., "your
employer does not appear to qualify as a public service employer on the basis marked on your ECF. Please review
and provide additional information if you believe our determination to be in error."
(pp. 20-22) and provides a customer service contact number. The message to the emplover
should be that the form is required. PHEAA will have to determine when alternative
documentation would be acceptable.
b. As an exception (or last alternative to receiving on ECF/and at PHEAA's discretion. 1fthe borrower is
still unable to obtain certification on the ECFbut employer is willing to generate an automated
certification. provide guidelines for acceptable alternative certification:
• The documentation is produced directly by the employer or by an entity under
contract with the employer to perform employment certifications:
• The documentation (e.g., letter, printout) contains all employment-related
information necessary to support PSLFeligibility, which includes:
• Name of Organization;
• EIN of Organization;
• Address of Organization;
• Full-Time/Part-Time Status of the employee: and
• Dates of Employment of the employee.
• The documentation is signed and dated by an authorized official of the borrower's
employer; and:
• The documentation provides contact information for the authorized official.
3. Treatment of "Self-Certification - -Self-certification is permitted if the borrower is the sole

authorized official of an active organization.
a. Make 1 attempt to contact borrower to inquire if another official may certify: if not·
b. Solicit supporting evidence to verify employment period and work status:
Examples include W2s (required) & paystubs. If paystubs are not provided, verify if income from W2
reasonably supports hours worked for the period of employment.
4. No Authorized Official- This pertains to closed organizations. If this box is checked, all
information in Section 3 must be provided except for certification by employer. Borrower must
submit documentation that supports information provided in Items 2 and 3.
a. Item 2: solicit supporting evidence to verify employment period and FT/PT status, as
reported in Items 2a and 2b.
i. Examples include W2s (required) & paystubs. If paystubs are not provided,
verify that income from W2 reasonably supports hours worked for the period
of employment.
b. For organizations assumed to be defunct. Follow normal review process to confirm
this then:
i. If 501(c)3-check Pub 78's list of Recent Revocationsof 501(c)(3) Determinations
and the Auto Revocation List.
1. If qualifying status can't be confirmed, or for private not-for-profits,
follow ··second look·· procedures
2. If insufficient evidence is supplied by the borrower, Deny.
H. Examples
1. Employer is U.S. Air Force - EIN is not provided and type of public service organization is not
checked. Address is confirmed by web search as Air Force base.
a. Unable to obtain EIN on employer call. Deny
b. EIN obtained on employer call. Accept
2. Employer is "ABC Foundation" - EIN is provided, but type of public service organization is not
checked. EIN verified as a 501(c)(3) on IRS Pub 78. Accept
checked (item 3 box b). Employer verified as a 501(c)(3) through name/address on IRS Pub 78.
a. Unable to obtain EIN on call. Deny
b. EIN confirmed on call. Accept
checked (item 3 box b). Employer cannot be verified through name/address on IRS Pub 78.
Deny
From: !(b)(5)
To; FedLoan PSLF
Cc: E..!:!&...!.at:;
Battle Cynthia: Diane Freundel: !J.1.....J..Q.o; l{b)(5) I Odom Christian
Subject: [external]RE: RE: Re: Re: Re: Re: PSLF - American Bar Association
Date: 11/15/2016 04:38 PM
H1Kim,
Thank you again for providing details to us regarding the retraction process Moving forward, FSA
would like Lo review and approve all relraclior1 cases relaled Lo employment prior lo servicer
processing.
We envision that the process will be similar to the employer escalations currently forwarded to FSA
for review. Elleclive 1mmed1alely, we would like lo receive Lhe following informalion for each case
v1;i the PSLFin box (b)(5)
~--------"
Reason for the retraction,
Number of borrowers impacted,
Dale of lhe olde:,l approval,
A copy of the retraction letter,
[CF(s), and
any research that Fedloan has already conducted on the employer.
Since many of these retr;ict1ons are time-sens1t1ve, FSA l.'Jill make every effort to provide ;i dnision
back to FedLoan w1th1n 3 5 business days
Please lel us know if you have wr1cerns vvilh Lhis requesl or if you need addilior1al informalior1.
l(ind regards,
Taneka
From: l(b)(5J I
Sent: Thursday,October20, 2016 3:05 PM
To: Fedloan PSLF;l(b)(5J I
Cc: Battle, Cynthia; Diane Freundel;Utz, Jon; Tiongquico,Rene
Subject: RE: RE: Re: Re: Re: Re: PSLF- AmericanBar Association
Thar1k you, Kim. This 1sreally helplul 1nlormal1on VVe will discuss on Lh1s:,ide and will gel back Lo
you
Kind Regards,
Tanek;i
From: KimberlyA Myersl.=d On Behalf Of Fedloan PSLF

Sent: Tuesday,October18, 2016 3:53 PM
To: !(b)(51 I
Cc: Battle, Cynthia; Diane Freundel; 'Fedloan PSLF'; Utz, Jon; Tiongquico, Rene
Subject: Re: RE: Re: Re: Re: Re: PSLF - American Bar Association
Hi Tankea! Again, I apologize for the delay. I wanted to ensure I provided you with accurate details.
Overall it appears the Business Unit retracted a total of 320 employers, with a breakdown as follows: 4 in
2012, 37 in 2013, 123 in 2014, 64 in 2015 and 92 in 2016. These numbers also include the employers
that you are aware of. I know the Business Unit performed some clean-ups (specifically in 2014 and
Based on internal reviews (those outside of the employers we escalated to FSA), the breakdown of
retractions is as follows: 243 were deemed for-profit and 49 were deemed not-for-profit but not providing
a qualifying public service. There were some other miscellaneous retractions (e.g. we retracted the
approval to request additional clarifying information due to conflicting information received via a later
ECF, the borrower was determined to be a volunteer, etc). Just to note, some of the retractions were due
to the borrower providing inaccurate information on the initial ECF which wasn't identified until he/she
submitted a subsequent ECF with conflicting information.
Most of the retractions were due to processor error.
Please let me know if you have any questions. Thanks I
Kimberly A Myers
Compliance Services
kmyers@pheaa.oro
(717) 720-2630
I ro111 -~I
ekb~)(~5L) ,:;publicservice@ed.gov>
Il(b)(5)
"'Fedloan PSLF'" <FedLoanPSLF@pheaa.org>. !(b)(5)
al.
"Battle, Cynthia" ,:;Cynthia.Battle@ed.gov>,Diane Freundel ,:;df eo11uevvp11eaa.01g>. Jon" <Jon.Utz@ed.gov>. "Tiongquico.
Rene" <Rene T1onggu1co@edgov>
Dc1l~ 10/17/2016 03:52 PM
Si,,; ,xt [external]RE: Re: Re· Re: Re: PSLF • American Bar Assoc1at1on
Just 'Nanterl to follow-u::i to fnrl out 1fyou \Nere a::ile to f11rl out thf' avn,,ge nurnbe' of 'etract1011sthat arP ·ssuerl
by :>11=AA.
I ;rneka

To: 'Fedloan PSLF'; l(b)(5J I
Jo vou ~,;we an ide:i ot the average ~,u·nber ot retractions t~,;it :i'e issued bv .>Hl::1\/\on a yearly basis? 1\dditionally,
1.vourl you kllO\Na::iout how many ofthosR 'Ptract1011s arR for Pmp oyr'c: \Nho \Nf'rf' 11011-prof1tth,,t \/if' rletnrn11Rrl
did ~,at p'ovirle a qu:i ity ng se'v ce anrl those ·,vho PHl::/\1\just rletermined were to'-p'ofit?
Tcrilc1t"vclv, I would ,JV U1Jl WCwould l\e tu Le clWJT of ,ill Tlrc1l11ur1,, c,peuJlly lrl lhe 117,[cl"K(.'
w··,crc l··,c
retrc1ll1or1 1, go111goul yeJr, Jflcr l··,c oorruwv·, crnploy1T1e11t·s Jµµroved, ci",d be JL c lo cc:1/cw l··,c lettv, Lefore
going out to borrm~'ers V\le'IIwait to hear about the volu·ne that you ;i~,ticip:ite ·,ve 'Nould ~,eed to revie·,v :Jetore
making ;i~,y decisions
Thanks,
Hi Tanekal Historically, if an employer retraction is because of changing guidance. etc, we will escalate
those to you before taking action. However, if we discover internally that an employer was approved in
error by a processor (e.g. employer was accidentally approved but it was always for-profit). we will take
care of those internally and not escalate. Based on your wording below, would you now expect these
situations to be routed to you first before we take action, even though we know the approval an obvious
error?
We can definitely forward the retraction letter to you before they are sent to the borrower. Just for our
knowledge, would you expect to have a quick turnaround in reviewing these letters so that we can get
them out to the borrower as soon as possible?
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.oro
(717) 720-2630
From ekb~)(~5L)
-~l<oublicservice@ed.gov>
Tc- Fedloan PSLF <FedLoanPSLF@pheaa.org>
~;~ "Battle, Cynthia" ,:;Cynthia.Battle@ed.gov>, Diane Freundel ,:;dfreunde@pt1eaa.org>, "Utz, Jon" <Jon.Utz@ed.gov>. "Tiongquico,
Rene" <Rene Tiqngquico@ed gov>, ''Chialastri, Taneka'· <Taneka Chialastn@ed.gov>
Dc1l~ 10/12/2016 10:11 AM
Si,,; ,xt [external]Re· Re: Re: Re· PSLF - American Bar Assoc1at1on
Hi Kim,
I believe this already occurs, but wanted to confirm if all retractions of qualifying employment
for PSLFare routed to FSAfor review? If not, we would like to request that in the rare instance
PHEAAbelieves we need to retract an approval FSAis notified through this mailbox so that we
may review the circumstances of the retraction.
Moving forward, we would also like to review a copy of the retraction letter(s) before they are
sent to the borrower regarding their qualifying employment.
On this end, we are in the early stages of discussing ways that FSAcan improve StudentAid.gov
and other outlets to increase transparency regarding the PSLFprocess and eligiblity for non-
501(c)(3) employers providing qualifying public services. I'll make sure to provide PHEAAwith
an update as more information is available.
Kind Regards,
Taneka
From: Kimberly A Myers <krnycr~@pheac1.org> on behalf of Fed Loan PSLF<FedLoc1nPSLF@µhec1a.org>

Sent: Friday, October 7, 2016 1:52 PM
To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF, Utz, Jon; T1ongqu1co, Rene; Ch1alastr1,Taneka
Subject: Re: Re: Re Re: PSLF- American Bar Association
Hi Taneka! You are correct in you assumption for the retraction tab. The processed date is the date it
was approved. Essentially it all occurs in one step (the ECF is processed as an approval).
With the retraction letters, we had previously advised that the Business Unit that they need to include
more detail. Previously it was very generic (it just basically stated that the employer was retracted, but
didn't give much explanation as to why). It has gotten better. but we can certainly work more with the
Business Unit to "beef" up the denial letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From kb)/5) lkb)(5)
To FedLoan PSLF <FedLoanPSLF@pheaa org>

C~ "Battle, Cynthia" <Cynjh1a.Batjle@ed gov>, Diane Freundel <dfreunde@pheaa.org>, "Tiongquico, Rene,""~--,
<Rene.Tiqngquico@ed.gov>, "Chialastri, Taneka" <Taneka.Ch,alastri@ed gov>, ·utz, Jon" don.lJtz@ed.gov>, !(b~J(~5~)
0 -~
<PUblicserv1ce@edgov>
Dc1l~ 10/07/2016 01 :47 PM

s,.,1_~,t [external]Re: Re: Re: PSLF-American Bar Association
Hi Kim,
Quick question for the retraction tab - Is the processed column date the date that the
borrower's ECFwas approved?
(b)(5)
In regards to the retraction letter - r
(b)(5)
Thank you,
Taneka
From: Kimberly A Myers <kmyers@pheaa.org::, on behalf of Fed Loan PSLF<FedLoanPSLF@pheaa.org>

Sent: Friday, October 7, 2016 12:26:29 PM
To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF;T1ongquico, Rene, Chialastn, Taneka
Subject: Re: Re. Re PSLF-American Bar Association
Hi Tanekal I was able to pull together the information you requested (no pressure for a mid-Friday) : )
I attached a spreadsheet which provides the borrowers whose ECFs were approved then retracted, as
well as the borrowers whose ECFs were denied outright. The spreadsheet has two tabs with each cohort
of borrower.
For the borrower whose approval was retracted after 45 months, I included the letters we have on record.
There is one system generated denial letter, one system generated approval letter, and the manual
retraction letter. Just a head's up on the system generated denial letter. His ECF was originally not
complete, so the denial is for missing information. He returned another, complete, ECF which is the one
that was approved.
If there is anything else you need, please do not hesitate to ask. Password to follow. Thanks I
Kimberly A Myers
Compliance Services
kmyers@pheaa.oro
(717) 720-2630
Frrnn 0 -~I <publ•cserv,ce@ed

kb~J(~5LI gov>
I c• Kimberly A Myers <kr11yers@pheaa.org>
~;~ Diane Freundel <dfreunde@pt1eaa.org>, "Chialastri, Taneka" <Taneka.Ch1alastri@ed.gov>, "Tiongquico, Rene"
<Rene.Tiongquico@ed.gov>, "Battle, Cynthia"' <Cynthia.Battle@ed.gov>, Fedloan PSLF <FedLoanPSLF@pt1eaa.org>. ~!(b~)(~5)-~
<publ•cservice@ed
gov>
Date 10107/2016 10:28 AM

SL,,;_ecl [external]Re. Re: PSLF - American Bar Association
Hi Kim,
Would you be able to provide detailed information on the borrowers whose qualifying
employment was was outright denied for the American Bar Association as well as the
borrowers who were originally approved and received retractions to date.
If possible, we need a secure file listing the borrowers names, SSN, Employer EIN, the date
the ECFwas received, Processed, Approved, Denied, Retracted ,and Notes (if applicable).
Additionally, we would also like to see a few approval, denial and retraction letters for the
borrower who had their approval denied after 45 months.
My apologies for having to request this on a Friday but if your team can pull this information
as soon as possible we would appreciate it. Please let me know if you have concerns.
Thanks,
Taneka
From: Kimberly A Myers <kmyers(a!pheaa orfi>

To: Foss, Ian
Cc: Diane Freundel; Ch1alastr1,Taneka
Subject: Re: Re. PSLF-Amer1can Bar Assoc1at1on
Hi Ian! Attached is a redacted copy of the ECF and corresponding retraction letter to the borrower.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From "Foss. Ian" <lan.Foss@ed.gov>
To Kimberly A Myers <krnyers@pheaaorg>
~;~ Diane Freundel ,:;dfreunde@pt1eaa.org>,

"Chialastri, Taneka" <eTaneka.Ch1alastri@ed.gov>
C~llc 04113/2016 08:42 AM

SL,8_cct [external]Re. PSLF-Arnencan Bar Assoc1at1on
Can we get a copy of one of the retraction letters (redacted) and also confirm that the
organization claimed to be a non-501(c)(3) not-for-profit that was claiming to provide public
interest legal services. I realize that some may have come in as being from the 501(c)(3), even
if it were ultimately determined that the borrower didn't work there. So I'm asking about the
ones that came in directly from the ABA.
Hi Ian!
Based on the query the Business Unit performed, there were 9 borrowers who were denied outright and a
total of 19 that received retraction letters. Of the 19 who received retractions letter, 14 were picked up in
this most recent query the Business Unit ran.
The longest timeframe from the date the borrower was originally approved to the date retracted was 45
months. However, one thing to note for that particular borrower, the Business Unit only retracted about
10 months of employment (from 8/2011 to 5/2012).
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From '"Foss. Ian'" <lan.Foss@ed.gov>
To "'Kimberly A Myers"' <kmyers@pheaa org>
~;~ Diane Freundel <edfreunde@pt1eaa.org>,

"Chialastri, Taneka" <eTaneka.Ch1alastri@ed.gov>
C~llc 04108/2016 02:56 PM

SL,8_cct [external]RE: RE. PSLF - American Bar Association
C;rn vou give me a sense ot how many borrm~'ers received a ret'actio~, 'egarding the M3/\ and how m:Viy received
outright dr11als' Alco. for thoc:r rf'trartrd. hO\Nlong aftn tlw ap::iroval did tlw retr,,ct1011go out (forthP ::io"mwr
tor 'Nhom twas the 10~,gest)?

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we had forwarded any other "Bar" or
"Bar Associations" for review. Although we didn't escalate the employer, I know you also initially made a
determination on the American Immigration Lawyers Association (which Jeff Baker also drafted a letter to
the borrower that Taneka shared with us).
I know in the beginning we were struggling with associations in general and specifically organizations that
would qualify under the "public interest legal services" category. At one point, I know we had talked
through it over the phone, which gave us a clearer understanding of this category. Once we grasped
what organization would/would not qualify under this category, we internally made the decisions and only
In regards to the American Bar Association, we made the decision internally that they do not qualify and
provided this guidance to the Business Unit. As we received ECFs from borrowers employed by the
American Bar Association, we were denying.
I know in some instances there were borrowers who were certified as working in a qualifying arm of the
American Bar Association (e.g. American Bar Association Fund for Justice and Education under the EIN
36-6110299). If we had a reason to question it, we would request the borrower's W-2 to confirm who
actually paid the borrower. In most instances, the borrower turned out to be employed by the American
Bar Association directly under the EIN 36-0723150. In light of your decision on ACLU, we now have
reason to question this further.
We were recently escalated an account for the American Bar Association where the previous approval
had not been retracted. As a result, the Business Unit ran a query to identify and clean up those
borrowers who may have been approved under the American Bar Association in the past who should not
have been. This is most likely where the retraction of the previous approval came from.
Thanks I
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Frrnn ''Chialastri, Taneka''< Taneka Qhialastri@ed gov>

I c• "Foss, Ian" <1an.Fos5@ed.gov:>.Diane Freundel <dfreunde@pheaa.org:>. "'Kimberly A Myers"' <kmyers@pheaa.org>
I :-aIe 04/08/2016 12:02 PM
s,.,1.~,t [external]RE: PSLF -American Bar Association
"11la1,
don't s·1ow Jnylh1ng on record for the Arner1ca·1 Bcir Assoc1Jt1on I onlv hJve docurnentJl-0'1 of dec1s·0"1s·nJcle
reg,rd1··,g tile K111gCow·,ty 3c1r A~~oc·c1l1(J"i, Bc1rA550Clcll1017of s,111F·c111l1~lO,Slc1le Bc1· of VV1~lOll~lll, cl",d tile D1~l·"cl
of Columbia :\Jr
Th;rnks,
I ;rneka
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLF and the American Bar Association;, We just got a letter
saying we approved them and then retracted it several years later. I'm not finding record that I worked on it
Thanks,
addressees only. If you receive this message in eITor please delete or destroy this message
and/or attachments.
Code:PHEAA
From: Georga Winand

To; Nicole Shepley
Cc: Donald Cameron; Nathan Horick; Wilbert Pless Ill
Subject: **Due: 11/26/16** CFPBCase# 160928-000265 ~
-1Zi:ii26l (Unknown) - ((FD))
Date: 11/07/201612·54 PM
Attachments: PSLFA licat1on."df
wi h Ex~I n°•i n.
no acco"n' - FL<:CFPB - dis"utos "' If info no acco"n' Id.doc
Account#:
NONE
Due Date:
11/26/16
CFPB Inquiry:
see below
Summaryof Concerns:
customer is questioning information received concerning her employer not being
certified for PSLF
Summary of Research/Background:
• reviewed inquiry
• verified in all AES, FLS, oneLink unable to locate any accounts for customer
• submitted response for review
Summary Block:
Response:
Enclosures:
nLa
Writer's Checklist:
\\·riter's Checklist
Prelimina~· ~-\ction
E Identify the concem(s) request.is)
D Submit conl)laint
E Detenrune appropnate solul:lon
D Send adjustment(s) Exception Request
D Reach out to party by phone (if applicable)
E ~otate tatl:
Preparing Response
G:::Ism es fully addressed m obJ ecc1-..-e

manner
G:::Template langwge ~-..-a~usted pronoW1s names (1f applicable'!
G:::Font size and spacmg
E Acronnns are defined at first lll5tance
E Correct s1gm.ture block
D Enclosure(s) ,nth appropnate parties cc -d
D Gather enclosures. e g :\[P);, disclosure statements. etc.
E AccoW1t= 1s correct
Rea~· for Edit
G:::Prepare e-ma.il templa.te e.g. acct::::. obJecti,·e sun111.ia.~,.:

block. enclosures. etc
G:::);otate task
Georga Winand
Borrower Experience Advocate
Consumer Complaint Management
717-720-3740
Forwarded by Georga Winand/AES on 11/07/2016 12:49 PM----
Frrn11 VIP Escalated/AES

c Georga Winand/AES@PHEAA
D:1tc:- 11/07/2016 11 :52 AM Kb)(6) ;::::::;:t
S.JhJwJ Fw: CFPB Case# 160928-000265 ~L--~l(b~J)((~b6~))
I (Unknown) - ((FD))
S;c;ntby Georga Winand
Borrower Experience Advocate Team

American Education Services
Forwarded by Georga Winand/AES on 11/07/2016 11 :52 AM ----
Fro Ill VIP Escalated/AES

fo Mikell L Czermendy/AES@PHEAA
Cc: Jessica M Nieves/AES@PHEAA, VIP Escalated/AES@PHEAA
D:1te 10/04/201612:55 PM
S,Jbject Fw: CFPB Case# 160928-000265-l(b)(B) !(Unknown) - ((FD))
Sent by: Wilbert Pless Ill ~--~
Hi Mikell,
FedLoan Inquiry - After a review, we are unable to locate account for l(bl(6l
61
!(b1( IPlease attempt to locate this account.
NAME: NIA
ACCT#: NIA
Remember to image the inquiry and submit a complaint, as applicable.
Wilbert Pless 111

Fedloan Servicing
Forwarded by Wilbert Pless Ill/AES on 10/04/2016 10:34 AM----
From · Jessica M Nieves/AES

To: VIP Escalated/AES@PHEAA
Cc: Donald Cameron/PHEAA@pheaa, Wilbert Pless 111/AES@PHEAA
[)ate· 09/29/2016 09:46 AM
I
S"1bJcct: CFPB Case# 160928-000265 - lili:ij]jJl(b)(6) (Unknown) - ((FD))
What happened
Product:
Student loan: Federal student loan
Issue:
Dealing with my lender or servicer: Received bad information about my loan
Describe what happened:
Please note that this case is affiliated with [Case number: 160826-001442]. I am submitting
this complaint due to my experience with Fedloan Servicing concerning the PSLF program. In
2012, my colleague contacted the Department of Education inquiring as to whether her 50l(c)
(6) employer, the American Immigration Lawyers Association (AILA), was a qualifying
organization for purposes of PSLF. The Department of Education affirmed that the
organization was a qualifying organization under PSLF. When I submitted my PSLF
certification to Fedloan Servicing in March of 2014, I was denied by Fedloan Servicing
without explanation. The letter stated, "Organization does not qualify." Fedloan Servicing
subsequently revoked my colleague's PSLF eligibility claiming that our 50l(c)(6) organization
was not a "qualifying organization" for purposes of PSLF. I requested supervisory review of
my personal application but the only information that I received back from Fedloan Servicing
is that "organization does not qualify." Additionally, one ofFedloan Servicing employees told
me that she was unaware of any 50l(c)(6) organizations that were approved as "qualifying
organizations" under 34 CFR Section 685.2 t 9(b) for purposes of PSLF. This is denial is
contrary to the regulations because my 501(c)(6) organization clearly provides public
education and meets the requirements of a "public service organization" as defined by the
regulations. The Department states in the proposed rule (pg. 37705,
http://www.gpo.gov/fdsys/pkg/FR-2008-07-0 l/pdf/E8-14140.pdf), that the statutory definition
of "public service job" is meant to include "certain non-profit organizations that are not
qualified under 50l(c)(3) of the IRC, but that meet the other statutory requirements and
qualify as public service employers under HEA." Congress clearly defined "public service job
definition" in the HEA (http://www.gpo.gov/fdsys/pkg/PLA W-11 0pub1315/html/PLA W-
1topubl315.htm) to include both "public education" and "public interest law services."
Attachment
File Attachment
(b)(6)
Elli
PSLFA . . 82.97 KB)
6
01..2...,l.u..2=1-"4"("'b)
..( _..I '....J-""'-"'::::"'LJ.."-LL"-F-'R"-"s"'''"-'n»
-t(:'.bl:::( (704.42 KB)
. .._turllllmLlwun_,F-'-"s"
. ..,,_,Lf
Desired resolution
Desired resolution:
The fair resolution is for Fedloan Servicing to reinstate my organization's eligibility as a
"qualifying organization" for purposes of PSLF.
Consumer Information
First name:
~
Last name:
i(b)(6) I
Email Address:
(b)(6)
Phone:
(b)(6)
Street:
(b)(6)
City:
Washington
State:
DC
ZIP Code:
l(b)(6) I
Country:
United States
On behalf of myself:
Yes
On behalf of someone else:
No
Complainant is a service member:

No
Complainant is a dependent of a service member:
No
Product iuformatiou
Name on account:
~i(b)(6) I
Account/Loan number:
fb1(6) I
Company name:
Fedloan Servicing
State:
DC
Case Details
Case number:
160928-000265
Company status:
Sent to company
Sent to company:
09/28/2016 09:51
Respond by:
10/13/2016
Thank you,
Jessica Nieves
Department Supervisor
717-720-2414

1 iJ 201-\
Dear Ms.~
below.
1

PSLF Program.
Program.
AMERICAN
]MJl,IIGRATION
1331G StreetNW,Suite300
LAWYERS Washington,
DC20005
ASSOCIATION Phone:202.507.7600 I www.aila.org
I Fax:202.783.7853
FAX
To:U.S.Deptof Education FaxNo.: 1\1-720-[(o-z..g
~c..O.loo.,n ':;:ie,rv,(.!.·1,..,3.
From:~~ Date:
Re:PSLFProgram Pages(includingcoverpage):8
o Urgent or Review o Comment o Reply o Recycle
MessageBox:
Pleasereviewthe attachedapplicationfor the Public ServiceLoan Forgiveness(PSLF)

Program.Enclosedfor your reviewis the EmploymentCertificationfor PSLFand a
letter in support of this applicationfrom AILA. Pleasefeel call me with any further
questions.
Best Regards,
Rfil@J
liliiEIJA.~ Esq.
Liaison and Information Associate
Direct: 202.507.76271 Email: llynch@aila.org
American Immigration Lawyers Association

Main: 202.507.7600 I Fax: 202.783.78531 www.aila.org
1331 G Street NW, Suite 300, Washington, DC 20005
'.;~
§: 1••1!'"ltJ_.J
CM
t;.,,;;: ;;·
Theinformation
contai!ledinthiselectronic
message an<!anyattached documentsmaycontaincon~denlial
andprivileged informationthatIsfortllescle
useoftheinlendedrecipient{s).
II youareoottheintended notetha1,myunaL/lhonz.ed
rec1pi.::nt, review,
discloswe,copying, distribution,
oruseoftlle
contents
oflhiseleclronic
message oranyattacheddccuments Ifyouhavereceived
isprohibited, thiscommunication itlerror,pleasedestroyii andnotify
theAmericanImmigrationLa1V'jersAssociaticn
immec'Iately.
The American Immigration Lawyers Association (AHA) is !he national association of more than 13,000 attorneys and law professors
who p1acticeand teach immigration law. Alf .A Member attorneys represent U.S. families seeking permanent residence for close family
members, U.S. businesses seeking talent from the global marketplace, as well as foreign ~tudents, entertainers, athletes. and asylum seekers.
Founded in 1946, AILA is a nonpa1tisan, not-for-profit organization tl-.atprovides continuing legal education, information, professional
services, ~nd expertise through its 38 chapters and over 50 national committees.
AMERICAN
IMMIGRATION
LAWYERS
ASSOCIATION
March 19, 2014

Fedloan Servicing
P.O. Box 69184
Harrisburg, PA 17106-9184
RE:Public Service Loan Forgiveness Program
Dear Sir or Madam:
The American Immigration Lawyers Association (AILA) submits this letter to supplement its
request for certification as a qualifying "public service organization" for purposes of the Public
Service Loan Forgiveness (PSLF}program. AILA is a private, nonpartisan, 501(c)(6) not-for-profit
organization that provides public education services, and as such meets the requirements of a
1
"public service organization" set forth in 34 CFR§685.219(b).
Founded in 1946, the American Immigration lawyers Association (AILA) is the national
association of immigration lawyers established to promote justice, advocate for fair and
reasonable immigration law and policy, advance the quality of immigration and nationality law
and practice, and enhance the professional development of its members. As part of its
1Under 34 CFR 685.219(b), a public service organization means:

(1) A Federal, State, local, or Tribal government organization, agency, or entity;
(2) A public child or family service agency;
(3) A non-profit organization under section SG1(c)(3) of the Internal Revenue Code that is exempt
from taxation under section SOl(a) of the Internal Revenue Code;
(4) A Tribal college or university; or
(S) A private organization that-
(i) Provides the following public services: Emergency management, military service, public
safety, law enforcement, public interest law services, early childhood education (including
licensed or regulated child care, Head Start, and State funded pre-kindergarten), public
service for individuals with disabilities, and the elderly, public health (including nurses,
nurse practitioners, nurses in a clinical setting, and full-time professionals engaged in health
care practitioner occupations and health care support occupations, as such terms are defined
by the Bureau of Labor Statistics),publiceducation, public library services, school library or
other school-based services; and
(ii) ls UQ.f;a business organized for profit, a labor union, a partisan political
organization, or an organization engaged in religious activities, unless the qualifying
activities are unrelated to religious instruction, worship services, or any form of
proselytizing.
{emphasis added).
AILANationalOffice
1331GStreet
NW,Suite300,Washington,
DC20005
Phone:
202,507.7600 I www.aila.org
I Fax:202.783-7853
advocacy mission, AILA educates the public about the ways in which fair and reasonable U.S.
immigration laws and policy serve the national interest by reuniting American families, injecting
much-needed investment dollars into the U.S. economy and creating jobs, protecting refugees,
and providing U.S.employers with the flexibility they need to remain globally competitive.
Through its national office and chapters, AILA also promotes and supports the delivery of
competent, ethical, and lawful pro bono immigration services to the general public.
Under 34 CFR§685.219(b) 1 AILA qualifies as a "public service organization" because it is a

private, nonpartisan, 501(c)(6) not-for-profit organization that provides public education
services through the following:
• AILA's Website: AILA provides its members and the public with up-to-date information
on immigration law and policy primarily through its website, available at www.aila.org.
The website is updated daily with the latest immigration news and information. AILA
frequently posts resources such as Immigration Politics 2014 (AILA Doc. No. 12120666),
summaries of proposed/enacted immigration legislation (AILA Doc. No. 13041944),
analysis of administrative policy changes (AILA Doc. No. 12032760), pertinent
immigration news articles, legislative alerts and updates (AILA Doc. No.13020647),
current legislation (AILA Doc. No.14012141), congressional votes, congressional
communications (AILA Doc. No. 14013053), AILA letters to government officials on
select policy issues (AILA Doc. No. 14022643), amicus briefs (AILA Doc. No. 14021243),
2
and more.
AILA's website reaches a broad segment of the public that is interested in U.S.
immigration issues. Individuals who visit our website include immigration attorneys in
private practice, nonprofit immigration attorneys, government attorneys, media
representatives, U.S businesses, foreign nationals, members of Congress and their staff,
and other interested members of the public.
• Collaboration with 501(c){3) and Other Not-For-Profit Organizations: AILA works

closely with other 501(c)(3) and other not-for-profit organizations, in particular, its sister
501(c)(3) organization, the American Immigration Council, to provide accurate
information on immigration law and procedures to the public. 3 In addition, AILA
frequently collaborates with nonprofit organizations to produce white papers,
backgrounders, and regulatory comments on new or evolving immigration law
developments, and briefs of amicus curiae to assist courts in rendering impact decisions
on immigration law that are fair, reasonable, and consistent with the law. AILA is also a
partner of the Immigration Advocates Network (IAN), a collaborative effort of leading
2 These resources can be accessed by visiting www.aila.org and typing the AILAdocument number in the
search box in the top right corner.
3 The American Immigration Council (AIC), formerly the American Immigration Law Foundation (AILF),has a
mission to strengthen America by honoring our immigrant history and shaping how Americans think and act
towards immigration now and in the future. AICprovides support to AILA'sadvocacy efforts though its
research and materials, as well as it practice advisories and litigation through the Legal Action Center.
immigrants' rights organizations designed to increase access to justice for low-income

immigrants and strengthen the capacity of the organizations serving them. IAN
promotes effective and efficient communication, collaboration, and services among
immigration advocates and organizations by providing free, easily accessible, and
comprehensive on line resources and tools.
• Media Commentary: AILA staff, AILA leadership, and AILA members are contacted
frequently by national and local print and news media to provide analysis and
commentary on immigration law and policy developments because of their expertise in
the field.
• Legal Education Opportunities: AILA offers numerous legal education opportunities and
publications, which are available to the public. AILA's Education Department presents
in-person conferences, live webcasts, live audio and web seminars, and OnDemand
programs throughout the year on a variety of important and topical immigration issues.
AILA is the leading publisher of information and analyses serving the practicing
immigration lawyer, which includes books and resources used by law school,
government agencies, nonprofit organizations, and attorneys in private practice.
• Pro Bono Programs: AILA provides the public with pro bono service programs such as
AILA Citizenship Day and AILA Military Assistance Program. AILA Citizenship Day
provides free or low-cost assistance to eligible legal permanent residents who wish to
apply for U.S. citizenship, utilizing partnerships between AILA chapters across the
country and grassroots organizations. AILA Military Assistance Program (MAP} is a
collaborative effort between AILA and the Legal Assistance Offices (LAO) of the United
States military Judge Advocate General's (JAG) Corps that provides knowledgeable pro
bone legal counsel to men and women of the United States Armed Forces.
AILA is a private organization that provides the above public services; it is not a business
organized for profit, nor is it engaged in partisan or religious activities, and thus qualifies as a
public service organization for purposes of PSLF.If you have any questions, please feel free to
contact me directly at 202.507. 7650 or via e-mail at twaters@aila.org.
Sincerely,
Theresa A. Waters
Senior Director, HR and Administration
American lmmigration Lawyers Association
American Immigration Council
I Records COile:PSECf•XBCR
0MB No. 1845·0110
Form~pr=d
Exp. Date 11/3012014
Employment Certification for Public Service Loan Forgiveness (PSLF,-----~
William D. Ford Federal Direct Lo<1nProgrnm
WARNING: Any persoowho knowinglymakesa false Slatementor misrepresentation on this formor on anyaccompanyingdoc:umet1ts
is
subjectto penaltiesthat may indude fines,imprisonment,
or both, underthe U.S.Crim!nalCodeand 20 U.S.C.1097.

Read !he accompanyingInstructionsfor completingthis EmploymentCertificationfor Public Service Loan Forgiveness,Type or print using blue
or black ink. You must sign and date this form in Section 2 and an authorizedofficial from the public service organizationwhich
employs/employedyou must completelyfill out, sign, and date Section3. If any information is crossed out or altered in Sections 1 or 2, you must
initial beside the chance; anv chances in Section 3 must be initialed bv vour emolover.
Please
1a.SSN.
8'11(bW6f°ued
the Wlowioa iaformatioa □ Check rx
!IJis if any of your information has changed.
1b.DateofBirlh(MM-DD-YYYY)
(b)(6)
~-------------" "-----------~
2a. N~me llliRfilJ la:iimiJ A 2b. Former Name N/A
Last Eics1 M, (if applicable) First
I
Last
"'
"7cc"""--------------is:CC===c
3. Permanent Address .rbO)c(Bc)
Stree«Address
Washington
City
DC
Sa•
20 □ :36
"P
Mailing Address
{if different) Street Address City State Zip
4.AreaCQde/Telephone-Home ('-110 ) 688-3987 f.rea Code/Telephone - Olher N/A

5. E-mail (op1ional) (b)(B)
Before signing, carefu/Jy read the entire form, including the instructions and accompanying letter.
1 request that the Public Service Loan Forgiveness servicer, on behalf of the U.S. Department of Education (the Department),
accept this EmploymentCertification from the public service organization at which I am/was employed for purposes of qualifying
me for the Public Service Loan ForgivenessProgram. If I submit this form before I am eligible to apply for forgiveness,I request
that the PSLF servicer retain this certification form until I submit the Application for Public Service loan Forgiveness.
forgiveness to make information from those records available to the Department. including the Public Service Lo.an Forgiveness
servicer. I also authorize the Department and its respective agents and contractors, to contact me regarding this Employment
Certification, at the current or any future number that 1 provide for my cellular telephone or other wireless device using automated
telephone dialing equipment or artificial or prerecorded voice or text messages.
I understand that:
(1) I may only qualify for Public Service Loan Forgiveness after I have made 120 separate, on-time, qualifying monthly payments
on an eligible Direct Loan, after October 1, 2007, while employed full-time by a public service organization(s), or serving in a
full-time AmeriCorps or Peace Corps position, in accordance with the definitions in Section 5. These 120 payments do not
have to be consecutive;
more than one eligible public service organization and meet the full-time requirement:
(3) Only the remaining balance of my loan(s) after I have made the 120 separate, on-time, qualifying monthly payments and met
all other eligibility requirements of the PSLF Program may be forgiven:
(4) I am not required to submit any Employment Certification(s) before applying for loan forgiveness, but if I do, the PSLF servicer
will review each Employment Certification I submit to ensure that it is complete, will verify that my employer qualifies as a
public service organization, and that the lo.an payments I made during the period covered by the Employment Certification(s)
are qualifying payments, Following this review, the PSLF servicer will notify me in writing or electronically of the number of
qualifying payments I have made while employed in qualifying public service and the remaining number! must make before I
am eligible to apply for PSLF. I will also be notified in writing or electronically if the PSLF servicer determines that the form(s) I
submitted is incomplete or that my employment does not meet the qualifying criteria, including the reason(s) for the
determination(s), along with the steps I would need to take to complete this form, correct this information, and submit the
corrected or additional information to the PSLF servicer; and
120 qualifying payments and have submitted my loan forgiveness application. I understand that the law does not permit
partial forgiven s based on aking a lesser number of qualifying monthly payments while working at a qualifying public
b)(6)
03-1'1· '.2.0\L{
Date (MM-DD-YYYY)
Borrower Name ,kebellBel=--1

____ _.@ill6[Jell:6;wc_
__ _ Borrower SSN: 1.£1..!~l-ll:!l~H.l~tJ!.I

An authorized official (see Se<:tion 5) of the public service
See Section 3 of the acx:on,panying lnstructrons f-OrComplaling Employmlm/ Cer/ificetion for Pu~l,c
organization at which the borrower is/was employe(I must
Service Loan Forgiveness for deteile<.!info1mation on com~I Ii
nese lns/ru<.;lionsare also located atwww. n•~id ' " complete lhis section.
Jnstructlone for Authorized Official;
• Complelethis form only ff you are an authorized offic;al of the public service organization at which the borrower identified in Section , is/was employed or, if the
. borrower ls/was a full-time AmeriCorps Of Peace Corps volunteer, an authorized official of AmeriCorps or the Peace Corps.
Read Ille dafiM,ons in &!cCion s before completing ihis form .
.
• Type or print using blue or black ink. All fields must be complete(! if applicable. Your signature date must include month, day, and year (MM-00-YYYY) .
Provi<je all requested information for Items 1, 2, and 3 below. Complete the employer's certifica1ion at lhe botton, of this page, The Employment Certification form
. cannot be processed ;r the information requeste<I In this section is missing.

II you make any changes to the info,mation you provide ;n ihis section, you must initial each change .
Please return the completed form to the borrower. The U.S. Oepallment ofEdlfCa1ion or the PSLF serv,car may contact you for add,t;onal information or
documentation.
.
Instructions for Borrower when there is no Authorized Official:
□ Check this bo~ ifyoo are unable to obtain cert,l,cation from an authorized official, for example, because the organization no longerexlsls, Provide all re~uested
,nforma\ion for Items 1, 2, and 3 below. Forltem 1, list tlle organization's address from when yoo worked there, and consult yourW2. records for the EIN. Toe
,. Oenartmentwill (""'uire uou to submit additional evidence of w.urnuijlm<in" emnlo"ment. Do not submit sunnortinQ documents until req<.iestedto do so.
Information about the public service organization et which the borrower ls/was employed.
A11erican Irn11igration Lawyers Association

~ - 11,o IS, 5101'11'.)1
Public Service Organization Name Feslerally A5signesl Employer ID# (EIN)
,.
1331 Street
"' Suite
300, Washington DC 2000S
2. Borrower's Employment
(a) Dates of employment:

(MM-00-YYYY)
Status.
Start:
l(b)(6)
1-I 2 I O I t I 3 I End: ,o,s,.
M,. (2.., ,1'-1 0 I I
(If the borrower is still employed, Pl.II today's date)
(b) Borrower's employment status at your organization:
[XI Full-Time Avera;,e number of hou~ per week:~
0Part-Tlme Average number of hours per week· ___
For purposes of eligibility for PSLF, full-lime employment is defined as:

(1) Working in qualifying employment in one or more jobs for the greater of:
(A) An annual average of at least 30 hours per week or, for a contractual or employment period of at least 8 months, an average of 30 hours per
week: or
(BJ Unless the qualifying employmer1t is with two or more employers, the number of hours the employer conside~ full-time.
(2) Vacation or leave time provided by the employer or leave taken for a condition that is a qualifying reas011for leave under the Family and Medical
Leave Act of 1993, 29 U.S.C. 2612(a){1) and (3) is equivalent to hou~ woriled in qualifying employment
NOTE: A full-time AmeriCorps or Peace Corps volunteer is considered a full-lime employee for eligibility purposes for PSLF.
3. Type of Public Service Organi:zation, in accordance with the definition in Section 5 {check one):
(a) DA government organization (including a Federal, State, local or Tribal organization, agency or entity: a pt.1blic child or family service agency, ~
a Tribal college or university):
(b) D A non-profit, tax,exempt organi:zation under Section 501(c)(3) of the Internal Revenue Code,
(C) 181A private, non-profit organization (that is not a labor uni011or a partisan polilical organiz.ition) that provides at least one of the following public
services (check all that apply):
D
Emergency management,
0 Military service,
D
Public safety,
D
L.iwenforcement.
D
Public interest l.iw services,
D
8
Early childhood education (1nolud1ng licensed or regulated child care, Head Start, and State-funded pre-kindergarten),
Public service for individuals wiCh disabilities and the elderly,
Public heallh (including nurses, nurse practitioners, nurses in a clinical setting, and full-time professionals engaged in health care
practitioner occupations and health support occupations, as such terms are defined by 111aBureau of Labor Statistics).
lill Public education,
D
Public library services,
D
School library services, or
D
Other school-hased services.
NOTE as to c.itegories (b) and (c): For purposes of the full-lime requirement [Section 3, Item 2 (b) above), a borrower's qualifying employment does not
include time spent on job duties that are related to religious instruction, worship services, or any fo1m of prosel\f(izing.
I cerl1fy that the borrower identified in Secti01'1 1 abo\18 is/was employed at a public service organization. as indicated above, or is/was serving in an
AmeriCorps or Peace Corps position (in accordance with the definitions of these terms in Section 5) during the period identified in Item 2{a) of this section.
1~:tt
Theresa A Waters
. \.)_jq lo\
Official's Name (Printed)
Authorized Official's Title
03· 14· 20)~

(202 l 507-7600
Authorized Official's Sianature Aulhorized Official's Telenhone Todav's Date MM-DD-YYYY
Page2of4
SECnON 4: ELIGIBILITY REQUIREMENTS I TERMS AND CONDITIONS FOR PUBLIC SERVICE LOAN FORGIVENESS
You may obtain loan fQrgiveness umler this program if.
(1) You are not in default on the loan(s) for which forgiveness is requested.
(2) Except as provided below for AmeriCorps and Peace Corps volunteers, you ~ave made 120 separate, on-lime, qualifying monthly payments after October 1, 2007,
on lhe Direct Loan(s) forwhlcll you are requesting forgivooess undei- one or '!lore ot the following repaymenl plans--
The Income-Based Repayment (IBR) Plan;
The Income Contingent Repayment (ICR) Plan:
The 10•Year Standard Repayment Plan• (Standard Repayment Plan with a maximum 10-year repayment period): or
Any other Direct Loan repayment ,>Ian,bu! only paymenls that are at least equal to the moothly payment amount that would be required under lhe Standard
Repaymoot Plan with a 10-yearrepayment penod may be counted toward lhe required 120 payments.
In addition, each of the reqv1red120 separate, qllalifying monthly payments must have been made on tlme {no more tllan 15 days after the scheduled due dale)
and for 1hefull scheduled installment amount
• IMPORTANT: The Standard Repayment Plan for Direct ConsohdationLoans entered on or after July 1, 2006 have val")lingrepayment terms based on the loan
amount. For purposes of qualifying for Public Servioo Loan Forgiveness, mcnthly payments you make under the Standard Repaywent Plan on a Direct
Coosolidatlon Loan are only qualifying payments ;f ITlilde under1he 10-year ~payment term.
Note for AmeriCorps/Peace Corps volunteers: If you were an Ame:iCorps or Peace Corps volunteer, you may receive credit for making qualifying payments rf
you make a lump sum payment on an eligible loan for which you are seeking forgiveness by using all OJ part of a Segal Education Award recejved after :i year of
AmeriCorps service. or by using all or part of a Peace Corps transilion paymiant(~ ,he payment Is made within 6 months after you leave the Peace Corps). The
Departmentwjll consider the lump stJmpayment you have made as the equ...alentof qualifying payments equal to the lesser of:
(1) The number of payments resulting after dividing the amount of ,ha lump sum payment by the monthly payment amount you would have made under one of
the qualifyillg repayment plans IIsled above; or
(2) Twelve payments,
Peace Corps volunteers makin11an eligible lump som payment must do so within 6 months of the End Date, as reported in Section 3 by the authorized off,cial.
(3) You were/are employed full time by one or more public service organizationsor serving in a ful1-1;meAmeriC01psor Peace Corps positjon at the time you made
each of the required 120 qualifying monthly payments, at the time you apply for loan forgiveness, and at the time roan forgiveness is grantetl
NOTE: You are not petmitted to apply the same period of service to receive a benefit under the PSLF Program and CheTeacher Loan Forgiveciess, Service in Areas
of National Need, and Civil Legal Assistance Attorney Student Loan Repayment Programs.
You may not apply for PSLF until after you have met the eligibility requirements lis:ed above. Since only qualily,llg payments made after October 1, 2007, while
employed at a qualifying public service organization may be counted toward the required 120 payments, and borrowers may not apply for loan forgiveness until after
they have made all 120 payments, the earliest date 1hatany borrower will t>eeligible to apply for a/Id receive loan forgiveness is OctotJer2017. A PSLF Applicatioo will
be made availallle ,o the public before October 2017.
Eligible Loans
Loans that are eligible for Public SeNlce Loan Forgiveness are
• Federal Direct Stafford/Ford Loans (Direct Subsldil:ed Lo.ins)
• Federal Direct Unsubsidized Stafford/Ford Loans (Direct UnsubsidizedLoans)
• Fetieral Direct PLUS Loans (Direct PLUS Loans)
• Federal Direct Consolidation Loans (Direct Consolidation loans).
loans that are in default are not eligible fQrforgiveness.
Note: Federal Family Education Loan (FFEL) Program loans, Federal Perkins Loans, and certain Health Professions and Nursing Loans may be consolidated
into a Direct Consolidatlon loan. However, payments made on ,hese loans prior to consolidation 1010the Direct Loan Program are not qualifying
payments and are not counted toward ,he required 120 payments for PSLF.
Qualifying Payments
■ Separate, on-time. full mon1hlypayments made after October 1, 2007 under a qualifying Direct Loan repayment plan. A payment is considered on-time ii it is
made for the full scheduled installment amount no more than 15 days after the cue date for the paymen1.
• Qualifying Direct Loan repayment plans are:
The IBR Plan:
• The ICR Plan:
The 10-Year Standard Repayment Plan (Standard Repayment Plan wilh a maximum 10-yearrepayment period): and
Any other Direct Loan repayment plan, but only payments that are at least equal to the monthly payment amount that would be required under the
Standard Repayment Plan with a 10-year repayment period may be counted toward the required 120 monthly payments
Qualifyirig Emplovment
■ AmerlCorps position means a position approved by the Corporation for National and Community Service under Section 123 of ttle Nalional and
Community Service Acl of 1990 (42 U.S.C. 12573).
• An authorized offlclal is M official of a public service organization (including AmeriCorps 01 the Peace Co.-ps)who has acoess to 1heborrower's
employment or servjce records and Is authorized by the public service org,mization to certify the employment status of1he organization's employees or
former employees, or lhe service of AmeriCorps or Peace Corps volunteers.
■ An employee means an individual who is hired and paid by a public seNice 0<ganization.
■ Full-time means working in qualifying employmenl in one or more jobs for the greater of:
• An annual average or at least 30 hours per week or, for a contractual or employment period of at least a months, an average of 30 hours per week: or
• Unless the qualifying employment is w1lll lwo or more employers, the number of hours the employer considers full time.
Vacation or leave time provided by the em~oyer or leave taken for a condruonthat is a qualifying reason for leave under the Family and Medical Leave Act
of 1993. 29, U.S.C. 2612(a)(1) and (3) 1sequi~alent to hours worked in qualif;,ing employment
• Government amployoo means an individual who is employed by a local, State, Federal, or Tribal govemment but does not include a memtJerof the U S.
Congress.
• Law anforoement means service perlomied by an employee of a public service organ,zation that is publicly funded and whose principal ac~vities pertain to
cnme prevencion.cootrol or redllclion of crime, or the enforcement of criminal law.
• Military service f01uniformed members of U.S. Anned Forces or the National Guard means "active duty· service or "full-time Nafo,nal Guard duty· as
defined in Section 101(d)(1) and (d)(5) of Title 10 in CheUnited States Code, but does not incfude active duly for training or attendance at a service
PaQEl of4
school For civilians, m,ritaryserv,ce means service on behalf of the U.S. Aimed Forces or Ille National
Guard performed by an employee of a public
• PfilaceCorps position means a full-t,me a5,,;ignmentunder ChePeace Corps Act as provicledfor uncter
22 U.S.C. 2504.
• Public Interest law reflns to legal serv,ces prov,ctedby a put>licservice organizationthat are ftmded
in whole or in part by a local, Slate. Federal, orTritlal
g011ernmenc
• A public service organlz.itlon is
A Federal, State. local or Tribal government organization, agency or entil)i;
A public child or fam,ly service agency:
A non-?rofit organization under Section 501(c)(l) of CheInternal Revenue Code that is exemptfr<im taxation
under Section 501(a) of CheInternal
Revenue Code;
A Tribal college oruniv«sil\,; or
A private organization (that is not a labor union or a partisan political 0!'9ilnization)that provides
al least one of the following public services:
emergency management.
military service,
public safety,
• law enforcement,
• pubhc interest law services,
early dlildhood education (1ocludinglicensed or regulated child care, Head Start, and State funded pre-kindergane
n).
public service for individualswith disabilities and the elderly.
• public health (including nurses, nurse practi!ioners.nurses in a cilnical setting, and full-time professioaals
engaged In health care pracM,oner
occupations and health support occupations.as sucil tem,s are define<lby the Bureau of Labor Statistics),
public education,
public library services,
school library services, or
• other school-basedservices.
NOTE: For purposes or the lull-time requirement (Section 3, Item 2.(b) above), an individual borrower's
qualifying employmentwith a Seci,on 501{cX3) non-profit or
olher private put>lieservice organizatioo does not include time spent on job duties tf1atare related to religious
;nstruct,on.worsflip services, or any form of proselytizing
SECTION 6; WHERE TO SEND THE COMPLETED FORM

Send the completed Employment Celtif/catlon to:
Ifyouneed~elpcompletingthisloon,call:855·265·4038
U.S.Deparunentof Education If youuse a telecommunicati01ts
deviceforthe deaf (TDD),call: 800.722-S189
Fedloan Servicing
P.O. Box 69184
~rrisburg. PA 17106-9184
Qr Fax to:i17,72l>1628 Web site: www.MyFedLoan.org
SECTION T: IMPORTANT NOTICES
P!'lyacy Act Notice. The Privacy Act of 1974 {5 u.s C. 552a) requiresthat the following notice be provided
to you:
The authorities for colleciing Ille requested information from and about you are §421 et seq., §451 et
seq..§461 et seq., aoo §420L et seq. of the Higher EducallOnAct of
1965. as amended {Ille HEA) (20 U.S.C. 1071 et seq., 20 U.S.C. 1087a et seq., 20 U.S.C. 1087aa et
seq.. and 20 U.S.C. 1070g et seq.) and the authorities forcollecling
and using your Social Security Number (SSN) are §§426B(f) and 484(a)(4) of the HEA (20 U,S.C. 1078-2(1)
and 1091(a)(4))and §31001(i)(1) of the Debt Collection
ImprovementAC!of 1996 (31 U.S.C, 7701(cJ). Participalmg In tf1eWilliam D, Ford Federal Direct Loan
(Direct Loan) Program afld giving us )KlurSSN are vciuntary, but
you must provide the requested information. including your SSN. to participate.
Toe principal purposes for collecting the information on this form, including your SSN, are to verily your
identify. to determine your eligibilil)i to rooeive a Direct Loan, to
receive a benefit on a loan (such as a <Jeferment.lo!bearance, disdlarge, orforgiveaess). to permit tt,e
servicing of your loan(s), and, ,fit becomes necessary, to locate
you and to collect and report on your loon(s) if your toan(s)become delinquent orin delault. wealso
use your SSN as an account idenlifier and to permit you to access
your account information electronieaUy.
The information in yom file may be disclosed, on a ease-by-casebas,s or under a computer matdling
program, to third parties as authorized under routine uses in the
appropriatesystems of records notices.
Fot a loan, Cheroutine uses of the inforrnatlonthat we collect about you include. but are not limited to,
its disclosure tofe<leral, state, orlo~I agenc,es, to institutionsof
higher education. an<lto third party servicers to determine your eligibility to receive a loan, to investigate
possible fraud, and to verify compliance with fe<leralstudent
financial aid program regulations
In the event oflit,gation. we may send records lo the Department of Justice, a court, adjudicative body.
counsel, party. or witness if the disclosure ,s relevant and
necessary to the litigation. If this information. either alone or with other ,nforrnation,in<llcatesa potenlial
violation of law. we may send itto the appropriate authoril)i for
action. wemay send information to members of Congress if you ask 1hemto help you with federal student
aid questions. In circumstances in\j'<)lvingemployment
complaints, grievmtces, or disciplinary actions, we may disclose relevanl records b adJudieateor investigate
the ;ssues. If provided for by a collective bargaining
agreement we may disclose records to a labor organizatlon recognized under 5 U.S C. Chapter71
Disclosures may be made lo our contractors for the purpose of
performing any programmatic funcfion that requires disclosureof records. Before making any sucil d,sdosure,
we will require the conlractorto mainta,n Privacy Act
safeguards. Disclosures may also be made to qualified researchers under Privacy Act safe{luards.
Fore loan, the rouline uses of Chisinformation also include, but are not limited to, b disdosure to fe<Jeral,
state, or Iocal agencies, to private parties such as relatives,
present and former employers, business and personal associates. to creditors, to financial and educational
institutions. and to guaranty agencies to verify your identll)i, 10
determine your program eligibility and benefits. lo permit making, servicing, assigning, collecimg. adjusting,
or discharging your loan(s). to enforce the terms of lhe
loan(s), to lnvestigale possible fraud end to verify compliancewith federal student financial aid program
regulations, to locate you if you become delinquent in your loan
payments or if you defaulL or lo verify whether your debt qualifies tor discharge orcancellalion. To provide
default rate calculations, disclosures may be made to
guaranty agencies, to financial and educatiooal institutions, orto federal, state or local agencies. To
provide financial aid h,scoryinformat,on, <lisclosuresmay be made to
educatiooal Institutions. To assist program admlnlstratOl'Swith tracking refunds and caRCet~tions,disclosures
may be made to guaranty agencies, to financial and
ooucational institutions, or to federal or state agenciell. To provide a standardized metllod for educational
institutions to efficientjy submit student enrollment s1atus,
disclosures may be made to guarani), ageoccesorto f1nenclaland educatiOnalinsttut,ons. To counsel
you in repayment effons. disclosures may be made to guarani),
agencies, to financial and educational institu!loos, orto federal, state, or local agencies,
Paperwork Reduction Notice. Accordir,g to the Paperwork ReductionAct of 1995. no persons are
required to respond to a collection of information unless o1displays a
,;urrently valid OMS control number. Public reporting burden for ltlis correcfionof informationis estimated
to average 0.5 hour., (30 minutes) per response, ioclud,ng1ime
for reviewing instructions.searching existing data resources. gathering and maintaining the data needed.
and completing and reviewing the collection of information. The
obligat,on to respond to this collection is required to ob1aina oeneflt ·1naccordancewith 34 CFR 685.219,
Send comments regarding the burden estimate or any other
aspect of111iscollect,onof information, including suggestionsfor reducing this burden. to the U.S Department
of Educat,on.400 Maryland Ave., SW, Washingto11,DC
20210-4537 or e-mail ICDocketMgr@ed.govand referenceOMS Control Number 1845-0110. Note:
Please do not return the completed Employment Certification
for Public Service Loan Forgiveneaa to this address.
If you have comments or coneems regarding the status of your Individual subm;ssion of this
form, contact the PSLF servicer (see Section 6).
Page4of 4
fedloan·
~ *SERVICING
U.S. Depa.rtment of Education
I11formalion a.bout your f<klenJ student l,:ur,n
P.O. Box 69184 Harrisburg,PA 171□ 6·9184
Toll•free855-265•4038 • Int'! 717-720-1985
Fax 717-720-1628 • TTY: Dial 711
M-Th Samto 11pm, Fri. 8am to9pm ET
JUNS 14, 2014 www.MyFedLoan.org
liiill§[J A liiill§[J
1417 HOPKINSST NW
WASHINGTONDC 20036
RESPONSETO THE EMPLOYMENTCERTIFICATIONFORM YOU SUBMITTEDFOR THE PUBLIC

SERVICE LOAN FORGIVENESSPROGRAM
WHY WE ARE CONTACTINGYOU

We reviewed the Public Service Loan Forgiveness (PSLF)EmploymentCertificationform(s) you submitted and
determined that you may not participate in employment and payment tracking for the PSLF program at this time or that
additional information is needed to complete our review of your Employment Certificationform. See below for further
information and action you may need to take.
-
--
.-
·-
~-
·=
·=
NCDTLXH7:FN068ECFDN
XXXXXXXXXX MR --
•
-~
~=
:;;=-::
-=
WHAT ACTIONSYOU NEEDTO TAKE
If your eligibility status is:
MISSINGINFORMATION If you would like us to reconsider the EmploymentCertificationform, please
resubmit the form with all required fields completed. Your loans will remain
with your current servicer(s)until a valid ECF is submitted. NOTE: Missing
informationcould indicatethat the field was left blank; the informationprovided
was illegibleor was not exactly what was requested;or the informationwas
altered and the initialsof the amender were not present.
NOT ELIGIBLE- If you can provide additionalevidence or informationthat you believe qualifies
ORGANIZATIONDOES NOT you, please resubmitthe EmploymentCertificationform with the additional
QUALIFY information. For your reference, we have included the criteria necessary to be
eligible for PSLF.
NOT ELIGIBILE- NO Loan forgivenessunder this program is available only for Direct Loan Program
ELIGIBLE LOAN TYPE(S) loans. However,loans made under other federal student loan programs may
qualify for forgivenessifthey are consolidatedinto a Direct ConsolidationLoan
that is repaid under a qualifying repayment plan.
If you are interestedin consolidating your Federal Family Education Loan

(FFEL) Programor Perkinsloans into a Direct Consolidation Loan, please visit
www.loanconsolidation.ed.govfor more informationand an electronic
application.
If you cho.oseto consolidate,please contact us when the consolidation

process has been completed. You will need to complete a new Employment
Certificationform that includes a period of employment after the Direct
ConsolidationLoan is made and we will reevaluate your eligibility for PSLF.
NOTE: Only payments made on the Direct Consolidation loan will count
toward the required 120 monthly payments.
UNDER REVIEW Based on the informationyou provided, we are unable to determine if you
meet all of the requi'ements for the Public Service Loan Forgivenessprogram
and need to conduct a more thorough review. Once our review is complete,
we will provide you with additional details regarding your employmenteligibility
for the PSLFprogram.

You may apply for loan forgiveness after you have made 120 on-time qualifying payments. You must be working for
a qualifying public service organization at the time you submit the application for forgiveness and at the time the
remaining balance on your loan is forgiven. A final determinationof your eligibility for forgivenesswill occur upon
receipt of your application.
While applying for and receivingforgiveness, you must continue full-time employment with a qualifying public service
organization while making on-time qualifying payments under one of the approved repayment plans until you have
received notice that you may cease making paymentson your Direct Loan(s).
THINGS TO REMEMBER
Although we will maintaincopies of any documents that we receive, we recommend that you keep copies of an forms
that you submit and any supporting documentation regardingyour employment and the PSLF Program. We also
recommend that you submit an employment certificationannually so that we can update you on your progress toward
your forgiveness eligibilitydate. The EmploymentCertificationForm and additional information regardingthe program
can be found on our website at www.MyFedLoan.org/PSLF.
Note: In order to have any remaining loan balance to forgive under the PSLF Program, most of your payments must
be made under the Income-BasedRepayment (IBR), Pay As You Earn, or Income-ContingentRepayment(!CR)
Plans. However, you will pay more interest over time under these repaymeT)tplans if you are not ultimatelyeligible for
loan forgiveness under PSLF.
Prepayments generally will not count toward more than one qualifying payment and no partial forgivenessis available
for making less than 120 payments.
OBTAINED ADDITIONAL INFORMATION
BY STUDENT BORROWER YOU MAY
PROTECTION FIND
CENTER ANDHELPFUL
If you have any questions or need additionalassistance,our trained loan specialistsare here to help. You may contact
us at the number listed on the front of this letter.
ELIGIBILITY CRITERIA FOR PARTICIPATIONIN THE PUBLICSERVICE LOAN FORGIVENESSPROGRAM

You must have made 120 on-time, separate, monthlypayments after October 1, 2007, on the Direct Loan Program
loans for which forgiveness is requested. Paymentsmade prior to October 2, 2007 do not count toward meeting this
requirement. Each of the 120 monthly payments must be made for the full, scheduled installmentamount within 15
days of the due date.
• Income-Based Repayment(IBR) Plan (not availablefor parent Direct PLUS Loans or Direct
Consolidation Loans that repaid a parent PLUSLoan)
• Pay As You Earn Repayment Plan (not availablefor parent Direct PLUS Loans or Direct
Consolidation Loans that repaid a parent PLUSLoan)
• Income-ContingentRepayment (ICR) Plan (not availablefor parent Direct PLUS Loans or Direct
• Standard Repayment Plan with a 10-year repaymentperiod
• Any other Direct Loan Program repaymentplan; but only payments that are at least equal to the
monthly payment amount that would have been required under the Standard Repayment Plan with a 1a-year
repayment period may be counted toward the required 120 payments.
AmeriCorps or Peace Corps position at the time you make each qualifying payment. Organizationsthat meet the
definition of "public service organization"for purposes of the PSLF Program are listed below.
• A government organization (including a federal,state, local or tribal organization, agency, or entity;

a public child or family service agency; or a Tribal college or university);
• A non-profit, tax-exempt organization• under Section 501 (c)(3) of the Internal Revenue Code (includes most
not-for-profit private schools, colleges, anduniversities);
• A private, non-profit organization~(that is not a labor union or a partisan political organization)that
• Public safety
• Law enforcement
• Early childhood education (including licensedor regulated child care, Head Start, and State-funded
prekindergarten)
• Public service tor individualswith disabilitiesand the elderly
• Public health (including nurses, nurse practitioners,nurses in a clinical setting, and full-time professionals
engaged in health care practitioner occupationsand health support occupations)
• School library service, or other school-basedservices
*NOTE: For purposes of the full-time requirement (Section 3, Item 2.(b) of the ECF), your qualifying employment does
not include time spent on job duties that are related to religious instruction, worship services, or any form of
proselytizing.
NCDTLXH7:FN06BECFDN
XXXXXXXXXX MR
~~
Acct# no account
CLOSED WITH EXPLANATION
Loan Type: unknown
Summary block:
• In preparing a response, a full review was performed on the account. Specifically, the follO\ving steps
were taken.
FedLoan Servicing reviewed all servicing systems based on the inquiry.
FedLoan Servicing drafted a letter to the borrower, which has been uploaded to the CFPB portal.
(attached)
Explanation of closure:
Sec attached PDF file.
As explained more fully in the letter/packet of materials uploaded to the CFPB portal in response to the
individual's inquiry,
• FedLoan Servicing advised the borrower that we have reviewed our servicing systems and were unable to
locate an account associated with her.
• FedLoan Servicing advised the borro\ver since we do not services an account on her behalf, we would not
be able to respond further.
• FcdLoan Servicing advised the borrower of contact infonnation for a PSLF specialist.
• FcdLoan Servicing advised the borrower how to contact NS LOS to obtain either owner or servicer of the
her loans for additional information.
• FedLoan Servicing provided contact information.
No further actions are planned by FedLoan Servicing at this time.
f SERVICING
www.MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
November 7, 2016
l{b)(6) ll(b)(6) Transmitted via CFPB portal

1417 HOPKlNS ST NW Case# 160928-000265
WASHlNGTON DC 20036
RE: Your Student Loan Account
Dear Ms. l(b)(6)
This letter is a fonnal response to your inquiry received through the Consumer Financial Protection
Bureau (CFPB) concerning your student loan account. ,vhich we service for him on behalf of the U.S.
Department of Education
Your concern regarding your account, as we understand it, is that you are disputing information received
regarding the ability to qualify for Public Service Loan Forgiveness (PSLF) based on your employer.
FedLoan Servicing reviewed our servicing systems, and are unable to locate any account associated with
you. Please accept this letter as confirmation that FedLoan Servicing has no record of servicing an
educational loan for you, based upon the infonnation ,vithin your inquiry. Since we are unable to locate
an account for you, we regret, we are unable to respond to your request with any further information.
If you have fu11her questions concerning PSLF. we encourage you to visit MyFedLoan.org/PSLF for
more information. You may also call 855-265-4038 to speak with a FedLoan Servicing PSLF specialist.
You may obtain additional information regarding the ownership and servicing hist01y of your federal
student loans through the National Student Loan Data System (NSLDS) website, nslds.ed.gov, using your
FSA ID. If you have not yet created an FSA ID, she may use the "Create An FSA JD'' link to begin the
process of creating an FSA ID. NSLDS will provide a complete list of your federal student loans and the
contact information for the servicer of each.
If you have additional questions or concerns, please feel free to contact our office at 1-800-699-2908.
Loan counselors are available Monday through Friday from 8:00 a.m. to 9:00 p.m., Eastern Time.
Sincerely,
Shelly Bowman
Vice President, Loan Operations
gaw
cc: Consumer Financial Protection Uurcau
Fedloan Servicing• PO Box 69184 Harrisburg PA 17106-9184
From: Tt1eodore Herman

To; Mikell L Czermendy
Subject: AILAletter
Date: 10/07/2016 02:35 PM
Attachments: ~- Summarv Block - Incorrect Comoanv.doc
L___JCFPB 1nou1rv.odf
Here'sthat one I receivedand answered.
ID
Ted Herman
BorrowerExperienceAdvocate
Fedloan Servicing I PHEAA
PO Box 1845
717-720-7548
therman@pheaa.org
Fw: CFPB Case# 160826-001442fbl(BI l(NoAccount Number)- ((FD))

VIP Escalated Theodore Herman ~---~ 09/09/2016 02:53 PM
Nathan Horick
Jessica M Nieves, Wilbert Pless Ill, VIP Escalated
Hi Ted,
Please see the below CFPB inquiry and information from OCA.
_ l(b)(6) ~
Re: •ocA Review• Fw: CFPB Case# 160826-001442 -•---~~No Account Number)
-_J UC/\ M.i1ltJ,:r. VIP Escalated
,_, I yl,,r :;ilk·
Jess1:;a M Nieves. Nathan Hor1::.k.OCA Mailbox, Wilbert Pless Ill
3ased on the information contained in the FSA letter, I agree this should be closed as Incorrect Company and directed to the De~
Thank you.
Jffice of Consumer Advocacy

:Jlease address response to OCA Mailbox
Based on OCA's guidance, please draft an incorrect company response. We do not have an account for
~b)(6) I
Nathan Horick
Fedloan Servicing
----- Forwarded by Nathan Horick/PHEAA on 09/09/2016 02:51 PM -----
Frorn Jessica M Nieves/AES

To VIP Escalated/AES@PHEAA
Cc Donald Cameron/PHEAA@pheaa, Wilbert Pless III/AES@PHEAA, Nathan
Horick/PHEAA@PHEAA
Date 08/29/2016 07:35 AM
SulJwct CFPB Case# 160826-001442 -l(b)(6) INo Account Number) - ((FD))
This is new work. Please take the following actions.

Fed Loan Inquiry - PSLF Related - Does not appear to have an FD account...
1. Log task.
2. Assign task.
3. Place task into the Issue Tracking Database.
4. Create new entry on the Federal CFPB Tracking Sheet
5. Load into Compliance 360.
6. Forward this email to a team member to process.
Be sure to remind the team member to image the inquiry and submit a complaint,
as applicable.
What happened
Product:
Issue:
My organization was preliminarily approved as qualifying for the Public Service Loan
Forgiveness program. Later, FedLoan Servicing rescinded the prior approval, saying that my
organization did not actually qualify.
Attachment
File Attachment
12.10.2014 fbl(6l !Received PSLF Response from Ian Foss.pdf (704.42 KB) 1.pdf
Desired resolution
Desired resolution:
FedLoan Servicing and the Depat1ment of Education should reinstate any Public Service Loan
Forgiveness (PSLF) approvals (or, in other words. rescind any retroactive denials) and adopt the
broader interpretation of what organizations qualify for PSLF that the statute contemplates.
Salutation:
Ms
First name:
!(b)(6) I
Last name:
l(b)(6)
Email Address:
Phone:
fb)(6)
Street:
b)(6)
A!!e:
~
City:
!(b)(6)
State:
tb)(s1 I
ZIP Code:
KbJ(6)
Country:
United States
Yes
No
No
No
Product information
Name on account:
fb)(6)
fb)(6)
Company name:
Fed Loan Servicing
Case Details
Case number:
160826-001442
Company status:
Sent to company
Sent to company:
08/26/2016 15:24
Respond by:
09/10/2016
Thank you,
Jessica Nieves
717-720-2414
NAME: rl(61
ACCOU~ I# n/a
Type: Federal
INCORRECT COMPANY
United States Department of Education

Federal Student Aid
830 First Street, NE, \Yashington, DC 20202
202-377-3681
Summary:
The borrower requested that her employer, American Immigration Lawyers Association (AILA) be considered a
qualifying employer for the purposes of PSLF. The borrower received a determination from the US department
of Education, Federal Student Aid, that their employer is ineligible due to their status as a Section 501 (c )(6) and
not an entity under Section 501(c)(3) if the Internal Revenue Service Code. There is no record ofFedLoan
Servicing ever making a determination on this account, nor did they ever service loans for this borrower. Since
the Department's determination is final, any additional appeals or questions should be directed to them at the
contact information provided in their letter.
From: Tt1eodore Herman

To; Nicole Shepley
Cc: ,Jessica M Nieves: Donald Cameron
Subject: CFPBXdue -KbJ(6) I- acct# n/a Case# 160826-001442
Date: 11/20/201610·26 PM
Attachments: (b)(6) FPB 1n,,u1r"x2.ndf
FPBenclosure AILA.ndf
FPB in rr 'e, mrn~r I
FPB Case# 160826-001442.docx
Sumrnarv Block - Closed with Exnlanation.doc
Account#: n/a
Due Date:
CFPBInquiry:
lml
Summary of Concerns:
• Bwr requests their employer be considered an eligible employer for PSLF.
Summary of Research/Background:
• Bwr states that FSA and FLS have denied their employer as eligible for PSLF.
• There is no correspondencein filenet nor is there any indicationwe ever

serviced the loans.
• The bwr submitted a letter from FSA with a determination their employer is
ineligible, so we are, based on OCA advice, prior was returned as incorrect
company and urging them to contact the Department directly.
• Bwr resubmittedand now am providinga closedwith explanationresponse
to spell out that Fedloan Servicing cannot assit with determinations made
by the Department.
•
lml lml
Summary Block:
Response:
Enclosures:
n/a
Writer's Checklist:
Prelimina~· :\c1io11
D Submit,:~mpLa.11:t
_ D:Hflll~ a;,propnat: ,~b.itior.
.!... T ~mpLa.t~languag~ w adJUst~ pr'-'l:oum nam~, 'ti app);;;abl~ 1
.l.. Cou:,:t ;,~atll!: blod:
D Endorun',) ·.-,-itl:-oppropnat: pani•s ;;;;'d
Read}· forEdi1
Please Review and Advise.
Ted
Ted Herman
PO Box 1845
717-720-7548
therman@pheaa.org
NAME: l(b)(B)
ACCOUN'=T~#~N~/A~~
Type: Federal
CLOSED WITH EXPLANATION
Summary block:
• FedLoan Servicing is not the servicer of the loan(s).

• The U.S. Department of Education owns the loan(s).
• In preparing a response, a full revie\v \Vas performed on the account. Specifically, the following steps
were taken.
- FedLoan Servicing reviewed the Borrowers loan and account history to determine actions that
were taken on the account on what date.
- FedLoan Servicing reviewed the borrower's loan and servicing history on NSLDS.
- FedLoan Servicing drafted a letter to the borrower, which has been uploaded to the CFPB portal.
(attached)
Explanation of closure:
See attached PDF file.
As explained more fully m the letter/packet of materials uploaded to the CFPB portal m response to the
individual's inquiry,
• FedLoan Servicing does not and has never serviced the loan in accordance \Vith the terms of the signed
Promissory Note(s) executed by the borrO\ver and federal guidelines.
• FedLoan Servicing previously advised the borrower in an incorrect company response explaining the
Department of Education (Federal Student Aid) dctcnnincc the borrower's employer is not eligible for PSLF.
• FedLoan Servicing advised the b01rnwer that because of this determination, they are unable to assist the
borrower.
• FedLoan Servicing advised the borrower they will need to contact the Department directly in order to appeal
this decision and provided the address to appeal.
• FedLoan Servicing provided contact infomiation.
f SERVICING
MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
October 9, 2017
RE: Your Student Loan Account
Dear Ms.fbl(5l
~--~
This letter is a formal response to your inqmry received through the Consumer Financial
Protection Bureau (CFPB) concerning your student loan account, \Vhich \Ve service for you on
behalf of the U.S. Department of Education (the Department), Federal Student Aid (FSA).
Your concern regarding your account, as we understand it, is to appeal the denial of your
employer, American Immigrant Lawyers Association (AILA), as a qualifying employer for the
Public Service Loan Forgiveness (PSLF) program.
According to our records, on or about December 10, 2014, the Department determined that
AILA was no longer being considered a qualifying employer for PSLF. The Department, through
FSA, determined that your employer is ineligible due to their status as a Section 50l(c)(6) and
not an entity under Section 501(c)(3) if the Internal Revenue Service Code. There is no record of
FedLoan Servicing ever making a detennination on this account, nor did they ever service loans
for this borrower. While we regret the results of this determination, FedLoan Servicing is
limited in its ability to further assist you with this issue as the results of this detem1ination by the
Department are final.
Since the Department's detem1ination is final, any additional appeals or questions should be
directed to them at the contact information provided in their letter. If you have further questions
regarding this particular concern, please contact the Department directly at the address listed
below. As a servicer of Title IV loans, FedLoan Servicing is a designated servicer of loans
O\Vned by the Department and because they have previously denied your request, any appeal
must be sent directly to the Department.

Federal Student Aid
830 First Street, NE
\Yashington, DC 20202
202-377-3681

Page2
If you have additional questions or concerns regarding this letter, please feel free to contact our
office at 1-800-699-2908. Loan counselors are available Monday through Friday from 8:00 a.m.
to 9:00 p.m., Eastern Time.
Sincerely,
Shelly Bowman
Vice President, Loan Operations
cc: Consumer Financial Protection Bureau

Re: Fw: CFPBX due 9/10 for 15 days

51
1L(b_l(
_ --~f acct# no account -
Uploaded
Jessica M Nieves Nicole Shepley 09/20/2016 09:21 PM
Elizabeth Felty, Roxanne Millan, Theodore Herman, Wilbert Pless Ill
Hi all,
This response has been uploaded to the CFPB portal.
Ted - Please update/close the complaint, as applicable.
Thank you,
Jessica Nieves
717-720-2414
Nicole Shepley Hi Jessica, This response is ready to upload tot.. 09/20/201611:43.19AM
From Nicole Shepley/PHEAA

To. Jessica M Nieves/AES@PHEAA
Cc Theodore Herman/PHEAA@PHEAA, Wilbert Pless III/AES@PHEAA, Elizabeth
Felty/PHEAA@pheaa, Roxanne Millan/AES@PHEAA
Date
Subject.
09/20/201611:43AM
Fw: CFPBX due 9/10 for 15 days
fb 6
)( l
I_ acct# no account - RESPONSE READY TO
UPLOAD TO CFPB PORTAL - ·
Hi Jessica,
This response is ready to upload to the CFPB portal.
Case# 160826-001442
~-~
NAME: fLb_)(6~)
ACCOUNT# n/a
INCORRECT COMPANY
Type: Federal

Federal Student Aid
830 First Street, NE, Washington, DC 20202
202-377-3681
Summary:
The borrower requested that her employer, American Immigration Lawyers Association (AILA)
be considered a qualifying employer for the purposes of the Public Service Loan Forgiveness
(PSLF) program. The borrower received a determination from the U.S. Department of
Education, Federal Student Aid, that the employer was ineligible due to its status as an entity
under Section 50 l (c)(6), rather than an entity under Section 50 l(c )(3), of the Internal Revenue
Code.
There is no record of FedLoan Servicing making a determination on this account. In addition,

the account was not administered by FedLoan Servicing. Since the Department's determination
is final. any additional appeals or questions should be directed there by using the contact
information provided in its letter.
No fut1her actions are planned by FedLoan Servicing at this time.
Thanks,
Nicole Shepley
American Education Services
Consumer Complaint Management Department
717-720-3410 (Voice)
717-720-3945 (Fax)
nshepley@aesS uccess .org
----- Forwarded by Nicole Shepley/PHEAA on 09/20/2016 11 :31 AM-----
From Theodore Herman/PHEAA

To. Nicole Shepley/PHEAA@pheaa
Cc Jessica M Nieves/AES
Date 09/14/2016 12:23 PM
SubJect· 61
CFPBX due 9/10 for 15 days ~L(b_li_
__ ~~ acct# no account
Account#: n/a
Due Date: 9/10 for 15 days
CFPB Inquiry:
ml
6
crb_li_
_1--~PFPB inquiry.pdf
Summaryof Concerns:
• Bwr requests their employer be considered an eligible employer for PSLF.
Summaryof Research/Background:
• Bwr states that FSA and FLS have denied their employer as eligible for PSLF.
• There is no correspondence in filenet nor is there any indication we ever serviced the loans.
• The bwr submitted a letter from FSA with a determination their employer is ineligible, so we are,
based on OCA advice, returning this as incorrect company and urging them to contact the Depatment
directly.
SummaryBlock:
6
[attachment Lrb_l(
_1__ ~ Summary Block - Incorrect Company.doc" deleted by Nicole Shepley/PHEAA]
Response:
n/a
Enclosures:
n/a
Writer'sChecklist:
n/a
Please Review and Advise.
Ted
Ted Herman
PO Box 1845
717-720-7548
therman@pheaa.org
Oc:. 2Cl6'2 02FM P I
October 3, 2016
Re· Complaint Number l60826-001442
To Whom It May Concern,
I am responding to the email I received be!ow. I called CFPBat the number listed below, and the person I
spake with asked me to fax this information o this fax number, showing the Fed LoanServicingis the
correct companyto file a complaintagainst.Pleaselet me know if you needanyfurther information
Best,
l(b)(6) pigmi!il com
----------Forwardedmessage----------
From: Consumet Financial Ptotection Bureau <donotreply@consumerfinance.gov>
Date: Tue, Sep 27, 2016 at 10:27 AM
Subject: Your submission, [Case number: 160826-001442]
To:fbl(Bl ~gmail.com
Ple;:isegive us a call at (855) 411-CFPB(2372}-we need to get some additioml information regarding
your complaint. We sre unable to further processyour complaint until we hear from you.
- Pleasecontact us at (855) 411-CFPB(2372) between the hours of 8 a.m. and 8 p.m ET

- Referenceyour complaint number 160826-001442.
- Make sure you call us within the next 30 days.
- A member of our team will help you complete your complaint.
As soon aswe receivethis information, we c;;incontinue working on your complaint
you,
Consumer Finsndsl Protection Bureau consumerflnance.gov[855) 411-CFPB(2372)
10/03/2016 11 :52AM (GMT-04:00)

Oc:. 2Cl6'2 02FM (fo.G365 P. 2
FederalStudentAirj Pl'IO!JOs;,or.SOR QI
l/1e ~.MERICAN MIND Df.CI u~1\
Dear M~bJ(6J
In 2012, you corresponded wi1hMs. Maureen Dowling in the U.S. Departmentof Education's
{lhe Department's)Office of Innovationand Improvementconcerning the status of your
employer, the American ImmigrationLawyersAssociation (AILA), as a qualifying smployer for
purposes of the Public Service Loan Forgiveness(PSLF) Program.
Under the PSLF Program,borrowers of federal student loans made under the William 0. Ford
Federal Direct Loan Program (the Direct Loan Program)may qualify for forgivenessof their
remaining loan balance after they have made 120 qualifying paymentswhile employed full-time
by an eligible public service organization.Under section 455(m) of the Higher EducationAct of
1965, as amended [20 USC 10B7e(m)],and the implementing PSLF Prngram regulationsat 34
CFR 685.219(b), an eligible public service organizationis a government entity, a public child or
family service agency, an entity 1hatis tax-exempl under Section 501(c)(3) of the Internal
Revenue Code (IRC), a tribal college or university,or a private not-for-profitorganizationthat
provides certain types of public servicesas listed in paragraph (5)(i) of the definitionof "public
service organization''in 34 CFR 685.279(b).
Ms. Dowling referred your question to slaff at the Department'sFederal Student Aid office and
OHiceof PostsecondaryEducation,both of which ate responsible for the managementand
oversight oi the PSLF Program. Our preliminaryreview of your employer's status in 2012
suggested that AILA was a not-for-profitotganization that provided public Interest law services
This wouldmakeAILA a qualifyingemployerfor purposesof the PLSF Program.We relayed
this information to you 1hroughMs. Dowling.
Earlier this year. another employee of AILA submittedan Employment Certificetionfor Public
Service Loan Forgivenessfotm to FedLoanServicing, the Departrnent'sdesignated federal
Sludent loan servicer for borrowers who are seeking a determination of whether their
employmen1and payments qualify for the PSLF Program. Upon receipt of an Employment
Certification tor Public $e1ViceLoan Forgivenessform, FedLoan Servicing is responsiblefor
employer tor purposes of the PSLF Program. In instances where FedLoan Ssrving cannot
dearly determine whether an employerqualifies, at least one Deparlment of Education manager
performs an additional review and, if necessary,consul1swith the Department'sOffice of
General Counsel, before a final determinationof the employer's status is made and
communicated to lhe borrower. This was the process used fallowing receipt of the AILA
employee's submission of the Employment Certificarionfor Public Servir.:eLoan Forgiveness
form to Fedloan Serving. Through tills mare thorough review process1 we deterrr1inedthat
Al LA is not a qualifying employerfor purposesof the PSLF Program, lor lhe reasons explained
below.
We determined that AILA is a private not-for-profitorganiza1ionthat is tax-exemptunder section

501(c}(6) oi the IRC. Because A/LA is not a tax-exempt entity under Section 501(c}(3) of the
Internal Revenue Code, it can only qualify as an eligibreemployer for purposesof 1hePSLF
Program if it provides one of the public services listed in paragraph (5)(i) of !lie regulatory
definition of "publfc service organization." Qualifying !ypes of publlc service that we considered
included public education and public interesl law..
&30 r- •~I Strl?.,3(. NC Na~l11·1gt,:,11 DC 202C2

1
~ludc-nt.A,rj g.~J
10/03/2016 11 :52AM (GMT-04:00)

Oc:. 2Cl6'2 02FM (fo.G365 P. 3
The EmploymentCertificationfor PublicServiceLoan Forgivenessform that Fedloan Servicing

received from the AILA employs@indicatedthat AILA provides"public educationservices". Our
researchshows lhat AILA is a professionalbar associationprimarilyengaged in advocacyand
providing news and commentaryon Immigrationissues to its members.and to the public In
general.For PSLFpurposes,the Department
considers"publiceducalionservices~
to be
services that provide educationalenrichmentor support directly to students or their families in a
school or a schooHike setting, BecauseAIL.A'seducationalactivitiesare directedprimarilyto ils
school or school-like setting,AILA does not provide public educationfor the purposes of the
PSLF Program
We also reconsidered whether AILA providespublic interest law services. For purposesof the
PSLF Program, "public ln1erestlaw" is delined in 34 CFR 685.2191b)as "legal services
provided by a public service organizationthat are funded in whole or in part by a local, Slate,
Federal, or Tribal government" After further review,we determ:nedthat employeesof AILA do
attorneys.AIL.A's"find a lawyer" site at www,,aj]alfill'i_er.com
specificallystates that AILA and
ailalawyer.com offer "no legal advice, recommendations,mediation. or counseling under any
circumstance,"but merely assist individualsin linding an attorney.
Based on our more thorough review of AILA'Sstatus, and notwilhs1anding1heInformal

information we provided in 2012, we have determined that AILA Is not a qualifying employerlor
but we must comply with all relevant statutory and rsgulatory requirementsfor the PSLF
Program.
It you have furlher questions concerning our determinationof AlLA's status or the PSLF
Program, please contact Ian Foss of my staff, at ian.foss@ed.govor 202-377-3681
Sine (b)( 6l
Jeff er, irec or

Poli y Liaison and Implementation
Federal Student Aid
U S. Departmentof Education
10/03/2016 11 :52AM (GMT-04:00)

VIP Escalated
5
Fw: CFPB Case# 160826-001442 1( I
Theodore Herman ~---~
f' ~nknown)- ((FD))
10/28/2016 11:07 AM
Wilbert Pless Ill
Jessica M Nieves, VIP Escalated
Good morning, Ted!
Fed Loan Inquiry - Please be aware, you have previously or are currently
responding to this complainant.
Wilbert Pless Ill

Fedloan Servicing
----- Forwarded by Wilbert Pless Ill/AES on 10/28/2016 09:24 AM-----
From Jessica M Nieves/AES

To. VIP Escalated/AES@PHEAA
Cc Donald Cameron/PHEAA@pheaa, Wilbert Pless I11/AES@PHEAA, Nathan
Horick/PHEAA@PHEAA
Date 10/28/2016 08:45 AM
SubJect. CFPB Case# 160826-001442 -f)(B) tunknown}- ((FD})
What happened
Product:
Issue:
My organization was preliminarily approved as qualifying for the Public Service Loan
Forgiveness program. Later, FedLoan Servicing rescinded the prior approval, saying that my
organization did not actually qualify.
Attachment
File Attachment
12.10.2014 ~rb~l(6-l--~1Received PSLF Response from Ian Foss.pdf (704.42 KB)
lml
12.10.2014+1(b)(6l fReceived+PSLF+Response+from+lan+Foss.pdf
20161003l055FAX-MABL-23 l610031552301443.PDF (89.35 KB)
"""
201610031055FAX-MABL-23_ 1610031552301443.pdf
Desired resolution
Desired resolution:
FedLoan Servicing and the Depat1ment of Education should reinstate any Public Service Loan
Forgiveness (PSLF) approvals (or, in other words. rescind any retroactive denials) and adopt the
broader interpretation of what organizations qualify for PSLF that the statute contemplates.
Salutation:
Ms
First name:
fb)(6)
Last name:
fb)(6)
Email Address:
b)(6)
Phone:
Street:
(b)(6)
Age:
KbJ(6) I
City:
State:
~
ZIP Code:
rb)(6) i
Country:
United States
Yes
No
No
No
Product information
Name on account:
fb1(6) I
fb1(6)
Company name:
Fed Loan Servicing
Case Details
Case number:
160826-001442
Company status:
Sent to company
Sent to company:
I 0/27/2016 12: 13
Respond by:
11/11/2016
Thank you,
Jessica Nieves
717-720-2414

1 iJ 201-\
Dear Ms.~
below.
1

PSLF Program.
Program.
Sincerelv, /I
~(b"")(+6)~~~~-----~
Jeff i;)a,"'1ZTJTre"'1:rr-----~
Poli Sy Liaison and Implementation
Federal Student Aid
From: Foss Ian

To; FedLoan PSLF
Cc: l{b)(5) I
Chialastri Taneka: Battle Cynthia: ,Johnson Debbe
Subject: FW: Public Service Loan Forgiveness Elig1bilt1yof the American Immigration Lawyers Association
Date: 12/10/2014 03:38 PM
Attachments: PSLF AILA 20141210 Final.pd!
FYI.
From: Foss, Ian

Sent: Wednesday, December 10, 2014 3:31 PM
To: !(bl(BI I
Cc: Dowling, Maureen; Mclarnon, Gail; Moran, Pamela; Arnold, Nathan; Smith, Brian; Utz, Jon
Subject: Public Service Loan Forgiveness Eligibiltiy of the American Immigration Lawyers Association
Dear Ms. l(b)(6J I

Attached is letter from Jeff Baker, Director of Policy Liaison and Implementation at Federal Student
Aid, which is an office in the U.S. Department of Education. His letter is in response to your 2014
follow-up inquiry concerning the eligibility of employees of the American Immigration Lawyers
Association for the Public Service Loan Forgiveness Program. I hope you find this response useful in
understanding our decision concerning the American Immigration Lawyers Association.
Kind regards,
Ian Foss
Policy Liaison & Implementation
Federal Student Aid
From: Foss Ian

To; FedLoan PSLF
Cc: l{b)(5) I
Chialastri Taneka: Battle Cynthia: ,Johnson Debbe
Date: 12/10/2014 03:38 PM
FYI.
From: Foss, Ian

To: !(bl(BI I
Cc: Dowling, Maureen; Mclarnon, Gail; Moran, Pamela; Arnold, Nathan; Smith, Brian; Utz, Jon
Dear Ms. l(b)(6J I

Kind regards,
Ian Foss
Federal Student Aid
From: Foss Ian

To; Diane Freundel
Subject: Fwd: Public Service Loan Forgiveness Program
Date: 06/30/2014 11 :22 AM
I'm at NASFAA and don't have access to the PSLF mailbox. Did you escalate this one
to me?
Begin forwarded message:
From: "Mclarnon, Gail" <Gail.McLarnon@ed.gov>

Date: June 30, 2014 at 10:14:50 CDT
To: "Dowling, Maureen" <Maureen.Dowling@ed.gov>, "Utz, Jon"
<Jon.Utz@ed.gov>, "Smith, Brian" <Brian.Smith@ed.gov>, "Moran,
Pamela" <Pamela.Moran@ed.gov>, "Foss, Ian" <lan.Foss@ed.gov>
Subject: RE: Public Service Loan Forgiveness Program
Maureen, I am out of the office until Wednesday. I will follow up with you when I
return.
Sent from my Windows Phone
From: Dowling, Maureen

Sent: 6/30/2014 8:08 AM
To: McLarnon Gail
Subject: FW· Public Service Loan Forgiveness Program
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From:~ I
l(b)(6) "(b~)(~6)~=~==---"
Sent: Sunday, June 29, 2014 1 :22 PM
To: Dowling, Maureen
Subject: Re: Public Service Loan Forgiveness Program
Hi Ms. Dowling!
I hope you're well and getting to enjoy the summer! I'm writing to follow up on
this email string from forever ago, in the hopes you have some advice. I'm not
sure if you remember, but I had contacted you about whether my position as a
Liaison Associate at the American Immigration Lawyers Association would count
as qualifying employment for the Public Service Loan Forgiveness Program. You
were very kind and forwarded my email to your colleagues at the Department of
Education who work in that area.
My coworker has since applied to have my organization recognized as a
qualifying organization (since we spoke, there's been an application process
introduced by which you can officially apply to have your current employment
count towards the necessary 10 years of qualifying employment). Unfortunately,
the application came back and said our organization didn't qualify. She called
and asked for supervisory review, and I think they're looking into it. The
application didn't give a reason that our organization didn't qualify.
I'm wondering if you know whether there is any other way to have the request
reviewed? I think there is an Ombudsman for the program, so we will look into
that option, as well. I know this isn't the area you work in at the Department of
Education, but I thought it wouldn't hurt to reach out! Any suggestions you have
for how we can follow up on the application would be much appreciated. I've
attached a copy of her application and the denial, in the event that it's helpful.
Thanks so much! Hope to see you soon.
Best,
~
On Mon, Jun 25, 2012 at 10:36 PM, l(bl(6l I~ (bl( 6l wrote:
Hi Ms. Dowling,
Thank you so very much! This is really helpful. I had many of the same thoughts
as your colleagues, but it is so reassuring to hear that others are on the same page.
Hope all is well!
Best.
On Wed, Jun 20, 2012 at 12:21 PM, Dowling, Maureen

<Maureen.Dowling@ed.gov> wrote:
Dear l(b)(6) I
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From: McLarnon, Gail
Sent: \X'ednesday,June 20, 2012 11:38 AM
To: Dmvling, Maureen
Cc: Foss, Ian; Moran, Pamela; Ctz,Jon; Smith, Brian
Subject: RE: Public Service Loan Foq.,-'1.veness
Prob.tram
Hi l\faureen, In order to qualify for public service loan forgiveness, a borrower must,
among other requirements, be employed full-time by a public service organization.
The policy staff in FSA and OPE believe that the American Immigration La'\vyers
Association meets the definition of public service organization in 34 CFR 685.219(b)
of the regulations because it is a private organization that provides public services, it
is not a business organized for profit, nor is it engaged in partisan or religious
activities. As a full-time employee of an elib-'1.ble
public service organization, Ms.
l(b)(6l I service would be considered eligible as long as she meets the rest of the
eligibility requirements in 34 CFR 685.219(c). I am including a link to the regulations
should she have further questions about her eligibility.
http://www.law.cornell.edu/cfr ltext/34/685.219
I hope this is helpful.
Gail
From: liliJj]]l(b)(6J I~(b~)(6_1
_______ ~
Sent: Friday, June 01, 2012 12:05 AM
To: Dowling. Maureen
Subject: Public Service Loan Forgiveness Program

Hi Ms. Dowling,
It was really great seeing you at the block party on Monday! It's always so
nice to make it out to my parents house and catch up with everyone.
I wanted to follow up with you on our discussion about the Public Service
Loan Forgiveness Program. I am trying to find out whether my current
position as a Liaison and Information Associate would count as qualifying
employment. I work for the American Immigration Lawyers Association,
which is a 501 (c)(6) organization. Do you have any ideas where I could go
to find an answer to my question? None of the information that I've seen
on the website or that I've gathered from talking with customer service
individuals seems conclusive. I've even looked through the statutes and
regulations, which seem to indicate it would qualify, but I'm not sure. I
have included below some background information on both AILA and my
position, but please feel free to let me know if you need more! Thanks so
much for your help, and I hope to see you soon!
!(b)(6) I
AILA: The American Immigration Lawyers Association (AILA) is the
national association of immigration lawyers established to promote justice,
advocate for fair and reasonable immigration law and policy, advance the
quality of immigration and nationality law and practice, and enhance the
professional development of its members. AILA has over 11,000 attorneys
and law professors members who practice and teach immigration law.
AILA Member attorneys represent U.S. families seeking permanent
residence for close family members, as well as U.S. businesses seeking
talent from the global marketplace. AILA Members also represent foreign
students, entertainers, athletes, and asylum seekers, often on a pro bona
basis. Founded in 1946, AILA is a nonpartisan, not-for-profit organization
that provides continuing legal education, information, professional
services, and expertise through its 36 chapters and over 50 national
committees.
Position Description: The Liaison and Information Department provides

direction to and coordination of agency liaison efforts, conducts
substantive legal research and analysis, and gathers and disseminates
information to members and the public. The Liaison and Information
Department works with liaison committees, the executive committee and
the board of governors to set and achieve liaison goals, and works with
government agencies to achieve those goals in close coordination with
other internal functions, including Advocacy, Communications, and the
LAC and IPC. The department also coordinates AILA participation in
coalition groups, responds to member questions, coordinates information
gathering and dissemination, and develops and manages lnfoNet and
other Internet-based dissemination programs. The Liaison and Information
Associate provides support to designated AILA liaison committees, and
coordinates assistance to AILA members with respect to information
needs. The Liaison and Information Associate maintains contact with
various agencies, monitors administrative developments, and seeks
answers to member questions/problems.
l(b)(6)
From: Brittany L Wagner

To: Brittany L Wagner
Subject: ID rive
Date: 12/23/2015 03:22 PM
Attachments: 2012 One docx
Paid Ahead Gu1dance.odf
Paid At1ead Status.odf
PSLF Procedural Change.Pd!.
PSO.xlsx
QPs.xlsx
getContent.odf
Master File-lnventorv NPPI & PII Repositories xlsx.
Eliq1ble.docx
Hello.docx
Good Moming.docx
FDTXJFS FDRP20 15276021150666836 .Pdf.
FDTXJFS FDRP20 15276021150667720 pd(
KB Article 11274 PSLF FAQs Q8 BU Edits 10.13.2015.docx
MPN.odf
Approved SSNs 10 08.2015.xlsx.
document1444153751630 xlsx
Plus Loans.xlsx
GA GP Cleanup 93015.xlsx
FWL42 10 01.2015.xlsx
TLF Dates xlsx.
pdl1 psv fov br /Autosaved).txt
S4_RCM DF01-07 Loan Discharge & Forgiveness 12.xls
D.Soloman 12 15 2015.docx
Public Service Loan Foro1veness- REPAYE UPDATES docx
FH Transfers 7.6.15.xlsx
20151109 PSLF GOG Man New Brwrs.txt
PCW Meeting.docx
Doc4.docx
SurvevExoort12 10 201512 28 13 PM.odf
New Layout Example - PSLF Manual Letters.docx
PSLF Pilot Stats.Pd!
PSLF Stats.xlsx
Conversion Reoort.docx
Ineligible Borrowers 11.09.2015.xlsx
Sample PSLF1 xlsx.
Sample PSLF.xlsx
Servicer Checks 11. 13. 15.xlsx
- Re_ Forms Wizard- PSECF.odf
PSECF-Completed Form odf.
PSECF- Form Preview pdf
Work.xlsm
Compliance Incident# 000364.odf
PLEASE READ - American Civil Liberties Union ACLU Pd(
GA GP Cleanup 103015 xlsx
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Brittany L Wagner
Production Support Analyst
D: 717.720.1965 I Bwagner@aessuccess.org
Public Service Loan Forgiveness (PSLF)

I FLSSERVICING,F
This topa: contains the: follov,,mg ~cction~:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
What is the PSLF Program?

The PSI F Program is intended to encourage individual~ to enter and continue to work full-time in public scrYicc
job~. The program allows eligible borrower~ to npply for forgi\•Cncsson the remaining bnlnncc of their Direct loans.
aJh:r sen mg full time at a public sen 1c..:organwllion for at ka~( 10 y..:ar~ \\hik making 120 quali!Ymg monthly
paymcnb after October 1, 2007.
General Information
If you rccci\'(: an incoming phone call and the borrower is 1\0 r n:quc:sting ~pccific information, please refer to the
following basic information regarding the program:
• Tl1i~progrnrn was cstabli~hcd to cncourngc incli\ iduah to enter and

cuntmu..: m full-tune public sen 1c..:cmploym..:nt by forg1nng the
remaining balance of their William])_ l·ord Direct Loan Program loan~
(Direct Loan~) after the borrO\\er ha~ made 120 separate. qualifying
monthly paymenb (begmnmg any tune aJh:r October I, 2007) while
employed full-time by a qualifyinµ public ~cn·ice organinnion.
'.J The borrower MUST ha\'e at lcaq one Direct l.oan to qualify.
~' Federal Direct Stafford/Ford Loans (Direct SubsidiLed Loans)
Federal Dir..:c( Lnsub~1diL..:dStafford/Ford Loan~ (Direct
Lnsubsidized Loans including l LACI I Loan~)
'.J 1-cderal Direct PI.LS Loans (Direct Pl.US I.oan~-parcnt or student)
~' Federal Direct Con~olidation Loan~ (Direct Con~olidation Loans)
Special Direct Consolidallon Loans
il 1-cdcral Direct joint (~pousal) Consolidation Loans
Note: To quali(\ for forgi\•Cne~~ora parent PLLS Loan. tl1e parent

borrower. not the stud..:n( on b..:halfufvdm the parent obtamed the Juan,
mu~t be employed by a public ~cn·ice organization.
• The borrower MUST make paymcnh under one of the following 1-.ligiblc
Repayment Plan~:
Pay As '{ou Earn Plan (PA YE) (no( available un parent Direct PLLS
Loan~ or Direct Consolidation Loans that paid a parent PLtJS Loan)
'.J lncome-Hascd Repayment (]HR) Plan (not aq1ilablc on parent Direct
PLU'l Loan~ or Direct Consolidation Loans that paid a parent PLU'l
Loan)
il Income-Contingent Repayment (ICR) Plan (not aniilable on parent
Direct Pl.US Loan~ or Direct Pl.US Con~olidation Loans)
~' Rc\i~ed Pav i\~ You Earn Plan (REP.-\YE) (not a\ailablc on parent
Direct PLUS Loan~ or Direct Con~olidation Loam that paid a parent
PLUS Loan)
'.J Standard Repayment Plan with a I0-year repayment period
~' Any other Direct Lonn Program repayment plan \\ ith payment~ tl1at
arc at lea~t equal tu the monthly payment amount that would have
been required under the Standard Rcpaymern Plan with a I 0-\"Car
repayment period
• Pa;-mcnt~ mu,! be ~t1blll1ttedt1rnel;-dt1ringqu,1l1ticd pCl'llllb lll
cmployme11t to count tm\:1rd, PSLI and mecl th,· follo1\·111grequirement~:

il l\o earlier than 30 day~ prior to the due date
'.J 1\ o later than 15 days after the due date
~' Full in~tallrncnt nrnount must be rccei\ed
If the borrower is reque~ting specific information concerning PSLL such a~:
• Wl1at i~ the ~tatu~ or my ECF'.'

I low many ufmy paymenb quali!Y 1
• I received a letter telling me I h;nc XX payments that qualify. but I \\Clllt

to knuw v,,hy the r..:s( ofmy paym..:nt~ Jtm-'+do not euunt'_!
• \Vhy wa~ my l:CF denied')
• Doc~ my employer quality··.'
• Wl1cn will my lonns be trnnsl'crred"!
Whrn will I be notified of how many paymenb quali!Y?
You must COLll transfer the call to the PSIS split, 6009.
If the borrower ~late~ they rccei\'cd a letter but you arc unable to locate an account for them, a~k the borrower if the
letter rcceiYcd reforcnecs the PSI.I-' program. lfso. ad\'i~c the borrower that you will be tran~fcrring them to a
dedicnted PSLF rcpre~entnti\e for furtl1er nssistnnce. COLD transfer the call to the PSLF split 6009.
Notepads on Accounts
>lotepnd~ nrc added to borto\\CT accounts where we 11,l\e nn Employment Certification Form record on
COMPASSsr,, with a s(a!Lt~ of approved, eunditionally approved. review. ur hold. Thi~ was done so that yuu can
identify thc~c account~ quickly If you ~cc the following notepad. plca~c cold tran~fcr the call to the l'SLJ· ~plit.
Denied borrower~ will also have a notepad on the account as long a~ the denial rca~on docs not ~rate -·no eligible
loans". Please do ,or delete these notepads arter speaking \\ith the borrO\\CTs.
Example
Viewable on ATC00:
FEDERAL
8ORROl1Efi
!WTEPAO
'I•'"·
:;~I'
-1 :, l'i, ,1_,,•,•_,.
02896 PRESS ENTERTO PROCEED

·le : ' 1I
Qualifying Employment (PSLF Split ONLY)
The borrower must be employed full-time b:- c1quc1lifying public service orgc1niLntion(s) or ~en-ing as c1full-time
Arm:nCorp~ or Peace Corps \ uluntccr while makmg the 120 qualifymg payments. Employment CcrtiJicatiun mu~t
be certified on an Lmploymcnt Certification Form (I.CF).
Full-Time Employment
1:u11-·1
imc employment means working in one or more jobs for the greater of:
• An nnnuc1l cl\•ernge ofat least 30 liours per week. or

• For a contractual ur employment pcnod of at least 8 months. an average of
30 hour~ per week; or
• Lnlcss the qualit~,ing employment i~ with two or more employers, the
number or hours tl1e employer con~ider~ Cull-time
Note: If a borrnwcr \\urb part-time for 2 or more quali!Ymg pubhc scrncc orgamLations. the employment 1s
considered full time if the sum of the m-cragc hours between the qualifying employers for which the borrower
concurremly worked totals at least 30 hours per week.
Public Service Organization

The Public Service Organin1tion must be one of the following.
• Gowrnment OrganiLation
il Including a federal. state, local. or tribal organinllion. agency, or
emity: a public child or family ~ervice agency; or a tribal college or
uni\•ersit:-. Excluding c1nymember of the U.S. Congress
• A non-profit. la.\-exempt organization under Section 501(c)(3) of the
Internal Rcn·nuc Code
'.J Includes most not-for-profit pri\'ate school~. colleges. and universities
• A private, non-profit organization (that is not a labor union or a
parfoan political organiLation) that prmide~ at lea~! one of the
folio\\ in:,: types of public ~crvicc:
l-"mer0e encv• mana 0e eme111
J\1ilitnr:- ~en-ice
Pubhc safety
il Law enforcement
'.J Public imercst law ~erv1ces
~' Enrly cl1ildhood educc1tion (including licensed or regulnted child cnre.
!!cad Start, and State funded pre-kindergarten)
il Public service for imli\'iduals with di~abilitic~ and the elderly
'.J Public health (including nurses, nurse practitioner~. nurses in a
clinicc1l ~wing. c1ndfull-time profc~sionc1b engnged in l1ec1lthcare
prnctitioner occupation~ and health support occupations, as such

itcm~ an: ddim:d by the 13ureau or Labor Statistic~)
il Public education
'.J Public library ~crvice~
~' School library sen ices. or
Other school-based sen JCcs
■ l\ok: A non-profit organi?ation only qualifies if the borrower·s
job duties arc unrelated to religious instruction. worship scrYiccs,
or pro~elytiLing.
Separation of Church and Stak
For non-prulit employer~. thelf employm.:nt can be related to rchgmn; howe\ .:r. their full time duti.:s must nut be
tied to thi~. Specifically, a borrower's qualifying employment may not include time spell! on job dutic~ that arc
related to religious instruction. worship scrYiccs, or any form ofpro~clyti1ing.
Sending the ECF

Horrowcr~ arc encouraged to complete the 1-.CI--·
while they arc making the 120 required payments. The 1-.CFmay be
~ubmittcd in one ol'tl1e following \,a:-~:
• Annually (recommended)
• \Vhcnc\'cr they change employers
• Wl1en tlicy appl:- for rorgivcnes~ under tl1c PSLF Progrnm
The ECF mu~t b.: ~upphed to th.: burro\\Tr upun request. The '·CO\ .:r Ldt.:r'· mclude~ qu.:stium for th.: burrower tu
complete to cn~urc their eligibility for PSLJ·. Prior to ~ending the !.Cl· packet, \Trif~· the borrower ha~ eligible loans.
1he I .CF i~ available for download and can be found under the Loan l·orgi\'encss link on our homepage. lf an FLS
borrower is unable to download the form. it can be scm by:
• Mail
c Send the form through l D22, select the ARC PSLJ·A.
• Email
r: u~e the Email \Veb~ite Link/Form button on Super Screen to email
fonn.
• 1:ax
c Submit the request u~ing the TS006 ARC in ATD22.
Note: Tl1e ECF package is also a\•ailablc on Student Aid on the Web and from the other l'cdernl loan servicer~.
Once the ECF form is processed, tl1e borrower will recei\e confirmation or qualifying employment and qualifying
Direct Loan paymenb (1fapphcablc).
b)(5)
~mail Campaign~--
ou.ir1,•11y l'',,LI Cllldil< ,11~,cm \cl th~ bo1nn1,·1, \\'170 .ire 1101,,n ,I bcn~lin,li rcp,1\·lll~lll pldll,
The c·t11~1] bdm1 \\111be sen( lo borro\\crs \\Im an: currcnllJ nrnl,lng
p~:, rnc·nh on an cl,::1blc n:p~J rnc·11lplan Ii c·. ",iandard) hLLl\\ 111haH: l1lllc
lo no hrnc·lil ~ltc·r rnak111gthe ru.1u11c·dI~() quail ti mg p~Jlllc·111, (F('] l '-
fedloan·
_._,,
Youneedtt>>eledad-_,-,entpl.infyoo-,tlt>re<>e<¥elhem<>'it
- from the Putii,c Se,...,.,~ F~sl'ml,.rn
#BOOROWER_NAA'Ell.
Alth"'9' yoo an, cum!<l!lymalang -- on..., @l,g- "'l"')'TI""'plan, you..,,, orno

MIO 11111@ balanc@ 1D
torg"'"
.lfl!!r makng )'<llr""IU- P"'fl'l"""-
What ....... Id I do?

You need 1Dmangol""' ,.,_,pl.in..,.
soon .as pou.,lo ID"""""' yoo """" tho n,g.>,eqpo,;..,.. -., to
bo<c,-gr,en
What repayment plan st>ould I choow?

You •hould "'""""" - of lhelollow,ng lr>e<>mH)~ R"l>'yment (IDR) pia,,.
Pay A• You Eam
looome-Bas@dRopaymom (IBRl
100001....cont.,gernR.,,...,,_ (ICRi
Th@yane all PSLF eligible ~d OOY<l~ua,yourmonlhly __,._ Howewr, fyoo •"' not ulbmatelyei,g,bl• for
PSLF. yoo m.:,yp;,y mon, ., ,n,..- _, trn• under th@so,_.,,,...... plan,;
◊ ','ew 3 ,,,, o' all ehg,Me n,pa)'TI~nt plan, fl;,,-PSLF
Get -=«l ~en! amount> and appt( foc a ,..., _,,.,,,, plan 1od.iy'
- r -·" , - "ru:><m
oaro 1,;,;
OR
Th,· ~rn,nl hdo11 1\Jll he ,c:,"l w bNnn1cr, \\lio arc· 1101on "n da:1hk
l"l'J'dJLnC[](plan ,n all (l ~- (ir"duaktl) dlld ,dio \\Jll IIOl h,ll~ dllJ
qual1 I} lng payrncnb rnuntcd unlcSa lhc:, "' llch lhrn rb11 I H' I 14 ,\R( ·1
fedloan·
-·-·
.,.._--.:::; - -,.CERVlt::l'I':;
ACTION REQUIRED
You ne«i to seled:.., eligible ~t plan for you,-~ts lo oount fur
Pi--= Setvice Lo.ri Forgr.rer,ess.
fflORROWER_NME#,
Hr, payment!, Iha! you make inoer you: current rep,3)111ent

plan will not co.ro1 toward Pubhc Service loan
Forg,-.ene-ss(PSLF)
What shoukt I do?

You need to change your ~t plan as soon as possible to ensure that any fuu'e pa<Jmentsyou make count
towards PSLF.
What re~ plan should I choose?

To haw the~ possible balance forgiven. yoo should con'!.lder one ol lhe following Income-Driven Repayment
(IDR) plans.
• P.iy ki You Earn

■ lncome---&:.sed Repaymenl (IBR)
• lncom~ Rep,ayrnent rlCRl
Thl.-y;ire all PSLF eligible ..,d ~ n.'d!J<.l'!-
you: monthly payment ~r. If you an.-,,ot ulllm.m'ly el,g,ble b'"
PSlF. you may pay more r1 interest over tme 117lder these repayment plans.
,) '✓,,;w .> ltst of all E-i>g,bl"a

rep;aym<cntpl;ansfur PSLF
Get esbmat!!d ~ amounts and apply' for a ,_ repa,,menl plan todayl

.,
,,.,r,,,
..,,,r:r
Atkr acn:s~ing the c:mail and ~igning imo their account the borrower
will be directed to the repayment plan ~election ~crccn.
1<:C063- ·1hi~ ARC will be: noted on l lD2A if the c:mail wa~ sent to the
borrower.
l<:CF Annual Reminder Email
Annual PSLJ· cmaib an: ~cnt to borrowc:rs who la~t hud un 1.mrloymcm Ccnificution 1:orm (LCI:) uppro\-cd one
year ago. The purpo~e of the email i~ to encourage the borrower to submit a new !-.Cl-'a~ a way to better track
quali(\ing paJment~ tO\\ard PSLF. Once this email is ~ent. it i~ nornted undertl1e EC171 ARC. A~ a re~ult of this
.:mail. \\T may s..:can mcn:a~c m mcommg ECF~.
1<:xamplc email:
'SERVICING
1: h,1s no·.-. tieen one \t"Jr snce ;our 1,1s1[mplo;m,;-n1 l::ert1!Ec,1t,cnform ,.[CF1 ',\.JS ,1pprcved Since :his ',\aS 1he 1,1".>\
,lppro·,ec Ei:F 1•,e ri.we on f1te ror ;·ou. ·.,e v.,1n1e,1\o t:"r,c,)w,l(je ,·0\1 10 sut.im1t .1 ne·~. one ,\S ,\,..,,\,.to ne1p ,ou tr,\Clo..
)'OW qu,1111\·,ngp.1,ments to·,·"ird PutJl!C Service Lo:in Forg1'1ene-s 1PSLf 1
As ;·ou m.J',· rnol'. \OLJ 1\,II h.J'le :o m.J<,e 1'.:!Oquat1l\1ng p.J,ments on \our lo.Jns 'l,h le emp10,ed full-11me b\ an
,ippro·,rt"d pulil1c St"f\11ceorg.1niz,1tion t;t"lor•! ,1ppt.1ng for lo,:in rorg,~ent"ss /111hough ;ou art" 1101 rt"qU.ft'd to re sulm1rt
,:m ECF ,1nnu.JII\ drnng so 1•,,11
l1elp ;ou i..eep '.r,1c-...of ;our proqress 10·.-.;:udPSLF el1q1Li111t;·
b\· conr.rminq tt1;:it vou <lre
.-,1,11
employed l'.1th a quar,!ier:l put11c ".>t•f'IIICt'organiz,1t,on
•·0·1111
)';'('f.i)'/1.·:1ti'i11 IJ
it:Ji:'::li':f:
HAVE ADDITIONAL QUESTIONS RELATED TO PSLF?
F fl{J <hf' ,rnsv.eis ;ou nf't>rl on our 1.,,1,-
Loan Conversion
Once an ECF is approved for a borrm,cr. any federally-l1cld loan~ tlicy ha\•e are tran~fcrred in approximate!:- 30-60
days to uur ~yst<.:m'""',
'{ou may encounter an account v,,h..:reit 1s past 60 day and the Juan~ still have not transferred.
R.e\'iew the chart hdow to determine what action need~ to he taken.
If a borrower is approved for PSLF and then The borrower must submit a new ECF to have their
consolidates ALL eligible loans newly consolidated loan transferred to us (only if
the borrower is still employed by a qualifying
employer).
Borrower has Direct Loans and FFELP loans and is Advise the borrower it will take 180+ days for the
approved for PSLF. They consolidate ONLY their loans to transfer from the date of disbursement of
FFELP loans and the transfer to FLS is rejected the consolidation loan. The Conversions
department will request the loans 180 days after
the disbursement.
If a borrower's ECF has been approved and they Access NSLDS to verify the loans are with a DOE
call stating they have loans with another servicer servicer.
• If this is the case, send an email to the FLS

PSLF Supervisor Review mailbox requesting to
have the loans transferred
• Your email must include the borrower's SSN,

DOB, and full name.
• Once your email is received. we will work with
Conversions to have the loans transferred
• If the loans are FFELP Loans serviced by a
commercial servicer, advise the borrower how
to consolidate to make them eligible for PSLF.
Taxable Income
According to the Internal RcYcnuc Service (IRS), student loan amount~ forgiven under PSI.F arc !\OT con~idcrcd
income for tax purpose~. For more information. the borrower should cl1cck with the IRS or their tax ach isor.
Super Screen Disposition Codes

'luper Screen Lfoposition code~ arc a\ailablc to provide better tracking ~peciCicto PSLF phone call~.
There arc four options available when you select PSI F. 1-.achoption ha~ its own list ofcfopo~ition codes to describe
the outcome of the pltone call
Consolidation
2. 1-.CF
3. Qualifying Payments
4. Repaym..:n( Plan
Cancel PSLF
!fa borrower with an approved FCF on file no longer want~ to pursue PSI F, populate a PSRI-.V ARC. ln your
comment. plea~e include the reason the borrower no longer wanb to pursue the program. En~ure your call comment
also mdica!<.:~th.: bonm\cr nu longer \\ants to pur~u..:PSLF.
There 1~ nothmg \\C du on our end to actually "cancel" a bonow..:r from PSLF. If the bono\\Cr do..:s not ~ubmit any
mrnT LCb to us, then we will not send any more apprond letters or payment tracking lct!crs to them.
We have crcat.:d th.: PSCJ\L - PSLF I30RRO\VER OPTOUT .'\RC to !1agitrack these account~. Wh..:n a PSREV
task i~ populated due to a rcquc~t to "cancel PSLI·". the PSC'.\JL ARC is created to en~urc that emails and other
PSI .I-"communication is not ~cnt to the~c borrower~.
Ifn new l·.CI- i~ rcc.:-iYcdafter th.:-l'SCl\l ta~k is populated it i~ prnccss.:-d a~ normal. If the !·.CF is appro\·,:-d, the
borru,\cr will re~ume rccei\illg cmaih and other PSLF curnmunic1tion.
Ifw.:- do not currently ~crTice the loans for th,:-horrowc1· requeqing to ··canc.:-1"PSI.I-. ~end an email to the I-LS
PSLF Supen 1~or Re\ 1cw inbox. En~urc the accou11t i~ l"ull;'.:-ommcnted a~ tu why the borruwcr i~ reque~ting tu
L·a1Kcl. DO l\"OT aLh 1~1.: the borrower that the loan~\\ ill not tran~kr lo fLS for sen 1nng.
PSREV ARC
An ARC. PSRE\'-PSLF :\CCT RV\>/ - LE:\D. ha~ been created for PSLF accounb that we ~en-ice \,l1ich require
\\"hl·n To Suhmit P~RE\'
• IDR issue~ related to PSU-' that potentially interfere with payment count
(i.e. !DR payments do not currently count tO\\ClTCb
PSLF. IDR not
procc~s..:d timely or corn:ctly, de.)
• l~~ucs with n::paymcnt plan that require additional review
• Harrower is requesting to opt out of PSI.F. Comments must indicate why
Ilic borro\\Cr i~ rcquc~ting to opt out.
• Whc:n the: borrower's loan~ \H:r<.: rcka~..:d \\i(hm the last 30 davs and th.:
borrowc:r did not n:ccin: a bill for the month(~) of the: tran~kr & the
borrower i~ requesting a bill. populate the PSR!-.V with the month(s) a bill
is being requested.
• Whc:n any ufthc folluwmg an: 1Tc..:1n:dto 1Tv1ewd1gibil1ty ur
employment/inconclusi\T ~tutus in the datahusc:
'.J W-2~
~' Pn:- 'ltubs
Proof of Qualil~'mg Public Serncc
il l'roofthat the organinition is no longer operational
Email FLS PSIS Supcn·i~or Rnic,,
• ,\11 nun-FLS accounts (not ~en-iced on our sy~tem) which reqmre review
• l~~ues with loan~ being transferred from unothcr ~cn·1ccr
RVECF - PSLF Review ECF

\\"hen To Submit RYECF
• Anytime a borrower or employer calls regurdinµ employer cliµibility

• \Vhen the borrower or employer is requesting the FCF to be reviewed
further
Email FLS PSLF ~uµl·ni~or Re,il'\\
\Vhen employment or an ECF need~ to be renev,,cd for a non-FLS borrower Inut sen JCcd un uur ~ystem).
RVPSI - PSLF Review IDR
Populate the R\'PSI ARC \\hen a borto\\er is requesting a review of their !DR Pinn. Thc~e tnsks arc working \\ithin
3-5 bu~m..:s~chty~. Some ..:x.ampk~ mclm.k, but arc not lurnt.:d to:
• IDR documentation that i~ logged under a different ARC ~uch as l.SOOX

or i~ atrnched to an ECF.
• ,\n IDR application that 1s rcc..:1vcdby email ur by c~calat.:d fax.
• A request to IT\·icw the accuracy ofan already processed JDR plan.
{Comment must include the rea~on the reYiew i~ being rcqueqed.)
RVWPS - Review PSLF Payments

This .'\RC 1s populated through ATD22 wh..:n rc\'lcwmg d1gibk paymcnb for PSLF. OR
When n borrower calb and requests to hnve their pnyment trncking proce~scd. c;,,.pcdited. or re\•iewed because they
do not agree/arc di~puting thclf payment cuunt.
PSCBK - PSLF Call Back Request

• Do '\JOT populate the PSCHK ARC.
• Tl1i~ARC should Ol\L '{ be populnted by the ~taffin Treasury
Management once a R \'WPS (a~k ha~ been cumpktcd. ur plac..:d un hold
due to u~ waiting for convcr~ion fik~ from a prn iou~ ~cr\'iccr.
• Requeqs submitted in this queue for any other rea~on will be clo~cd and
returned to tl1e person \\ho requested it.
How the .\RC Works
1his ARC wa~ created to ensure we arc communicating with the borrowers who arc requesting to ha\T their
payment tracking expedited. or further reYicwed. This ~hould prc\'cnt several ofthe~e borrowers from calling in
multiple time~. Below nre the ~tep~ ns to how thi~ procc~~ \\ ill work:
Horrower calls in to have payment tracking expedited. or payment count further rc\'iewed bccau~e of new
informntion received. or the:- do not ngree \\ith tl1eir pa:-mcnt count.
PSLF Rep takes call and then populate~ the RVWPS ARC to hav..: their paym..:nt tracking r..:\·1c\\ed
Rep in l reasury \tlanagcmcrn will work RV WPS 1ask
Once RV\VPS Task has been completed or placed on hold {u~ually due to mi~~ing conversion files). they will
populate the PSCBK ARC.
PSCl3K tasb will be a~s1gned daily.
Once the l'SCBK task i~ assigned. you will be ~ent an email letting you know the call back needs to be made.
Period of Service Restrictions

1he ~amc period of ~en·icc may not be used to qualify for l'SLI: and:
•
• Pubhc Sen-in: m Ar..:a~ uf'\/ational J\cc:d
• ·1he: Ci\·il Lcgal Attorney Assistam.T Student Loan lh::paymcnt Programs
(Thi~ program i~ no longer funded.)
PSLF Resources
The bono\\ l:r can find more 1nformation about the PSLF Program on W\\'\\ .l\lyFcdLoan.urg , I \lanagc ,\ccount,
Loan 1:orgi\'/:nc~~ and Discharge Program~. Public Scrvicc Loan Forgi\'l::nc~~). l he following n::sourccs an:
aq1ilabk:
• Empluy1m::nt Certification Form

• hcqucntly Asked Qm::stion~
• Step-by-step instructions
New York State Get On Your Feet Loan Forgiveness

Program
• Thi~ program prond..:s up to 24 months or !S:<lcralslulknt loan lkbt n:lid"
to recent '\Jew York Statc colk:gc graduate~ who arc participating in a
federal Income-Driven Repayment plan and whose payments arc
generally capped at IO percent ortheir discrctionar:- income. Pa:-rncnt~
made by >J..:w'{ork Stale:, umkr >ls:\\' Yurk ·~ Gc:t On '{ uur Feet Loan
l·orgi\·rnc:ss Program, will qualit~· a~ PSLI· raymrnts prmided they med
all other PSI F payment qualification~. Horrowcrs ~hould be tran~fcrrcd to
tl1c PSLF line (e;,,.t.6009) if they request inl'ormntion on whetl1cr payments
made un 1h..:1rbc:halfbv J\e\\ 'York State count towards the PSLF
rrogrum.
• The State of !\cw York imcnds to make paymcms directly to the
borrower"s fcdcrnl ~tudcnt loan servicer(~). pro\ided the borro\\CT
cuntmu..:s to m..:d th.: Program's reqmr..:menls.
• !\cw York will coordinate with scnicc:rs to determine: the borrower's due
date. payment amou111,and whether the income criteria i~ met.
• Re\ iC\\ the Knowledge Base article about
for more mformallon.
Escalated PSLF Calls

If you need to c~calatc a caller ba~cd on PSI.I--"details statu~. warm transfer the call to x5350.
Page 1 of 1
*Procedural Ch:mge*
Due to recent !-<SAguidance we arc no longer using the procedure that the full in~tallmcnt must be received within 20 days
prior to the due date, and no later than 15 days after the due date. If a borrower presents evidence, or a review of the collateral
Jiles show that prior to being transfcncd to FLS, another servicer billed them and they made the payment during the billing
period. the payment will be considered on time and count for PSLF.
To qualify for PSLF, the full installment (on an eligible repayment plan) must be received within the billing period for
that month, and no later than 15 days after the due date.
When reviewing collateral files from other serv1cers, we sec that some of the other serviccrs bill borrowers on different
ranges of billing cycles. For example, we have reviewed collateral files from ACS that showed a borrower was billed 28 days
prior to the due date, and another ACS file shows another borrower was billed 25 days before the due date.
Example: The botTower was billed by Aspire 25 days prior to the due date. on 2/03/2013. and their due date is the 28th. As
long as their qualifying payment is received between 2/03/2013 and 3/15/2013 it will count for PSLI-<.
Here is an example of a botrnwer that was billed more than 20 days prior to the due date:
2/28/11 NOTICE TYPE BILL - BILL SENT TO BORROWER ELECTRONICALLY EFFECTIVE

DATE WAS 3/28/11.
3/31/11 NOTICE TYPE BILL - BILL SENT TO BORROWER ELECTRONICALLY. EFFECTIVE

DATE WAS 4/28/11.

DATE WAS 5/28/11.

DATE WAS 6/28/11.
This borrower \Vas billed 28 days prior to the due date each month. As long as the following are met, the payments for each
month would count as long as they were received during the billing period, and no more than 15 days after the due date.
*bonower employed at a qualifying employer

*borrower on eligible repayment plan
*full installment received
We arc in the process of updating the PSTRK procedures to reflect th1~infonnation. Let me know if you have questions.
Thank you,
Jody Teter
Cu~tomer Service Supervisor
FedLoan Servicing
(717) 720-3245
https://collector-vip.aessuccess.org: 11443/ AFUWeb/afu _Jv5ywo-FQIOL4HB6nkqVIBp/l ... 10/27/2015

Page 1 of 1
This i~ the confirmation we received from FSA:
Here is the PSLF Paid Ahead guidance we provided to you orally in the 04/11/12 FSA/Fedloan meeting:
A borrower who is either partially or fully paid head may have subsequent payments made during paid ahead
status qualify for PSLFif they are for the full amount due under the repayment schedule (and otherwise qualify).
For example, if the repayment schedule dictates a repayment amount of $50, but the borrower pays $60 during
month one, that payment counts so long as it otherwise qualified. For month two, the borrower is billed for $40,
but pays $60. The payment made for month two qualifies if it otherwise qualifies. For month three, the
borrower is billed for $30, and pays $30. The payment made for month three does not qualify because the
borrower did not pay what was due on the repayment schedule.
Here's another example. If the borrower's repayment schedule dictates a payment amount of $50, but the
borrower pays $150 for months one, the borrower's due date is advanced two months. The borrower is billed
$50 for month four and pays $50. The borrower gets credits for two months: month one and month four. If the
borrower had paid $50 during months two and three, the borrower also would have gotten credit for those
months (being paid ahead for two full months notwithstanding).
Thank you,
Jody Teter
Customer Service Supervisor
FcdLoan Servicing
(717) 720-3245
https://collector-vip.aessuccess.org: 11443/ AFUWeb/afu _ghvkqOuplRR6FOBQx 7oECG ... 10/28/2015

From: Robert G Cameron

To: Gr11gan ,John C-
Cc: Bradley H11yett Eleanor: Colbert Ill Edward: Francella Carmen; 'Harshbarger Scott': ,Jamie Irwin;
jmw@stevenslee.com; Jason Swartley: James J Jarecki
Subject: PSLF ECF processing procedure and employer escalations 2012-2017
Date: 07/21/201712:05 PM
Attachments: Employer Escalations 2012 Final.xlsx
Employer Escalations 2013 Final.xlsx
Employer Escalations 2014 F1nal.xlsx
Employer Escalations 2015 F1nal.xlsx
Employment Cert1f1cat1onForm Review Manual pdf
John,
Attached below are the spreadsheets containing our evaluations of employer

escalations of ECFs since the inception of the program, and the Compliance ECF
processing procedures. Data elements of the employer escalations include the date
sent to compliance, dates escalated to and returned from FSA (when appropriate)
and comments from FSA and Compliance.
Please note that there are three sections in the ECF procedures that are incorrect at
this point due to updated FSA guidance. However, the FSA guidance is being
followed, and the procedures will be updated shortly. (The same person that
processes the ECF's in Compliance is the same person that updates the procedures.
We have recently tasked a 2nd person with updating the procedures.) The sections
are Section 2.2 - FSA advised we should be approving Tribal casinos as long as they
are under the auspices of the Tribe (regardless of whether they are profit making or
not); and Section 2.5 & 2.7 - FSA advised a private not-for-profit (non-501 (c)(3))
organization should be evaluated based on their "primary purpose").
Thanks,
Bob
711
L'J__j
711
L'J__j 711
L'J__j
711
L'J__j 711
L'J__j
Robert G. Cameron
Deputy Chief Counsel and Vice President of Enterprise Compliance
Legal and Compliance Services
PHEAA
1200 North Seventh Street
Harri~hurg, PA 17102-1444
Phone: 717.720.1555
Fax: 717.720.3933
Email: rcameron@pheaa.org
1
PIKBa .
Employment
Certification Form
Review Manual
EMPLOYMENT CERTIFICATION FORM REVIEW MANUAL
Table of Contents
Document Version Control .................................................................................... 3

Summary .................................................................................................................. 3
Acronyms ................................................................................................................. 3
Foundational Material ............................................................................................ 4
Section 1: PSLF Employer Database .................................................................... 5
1.1 Locate Escalated Employer ............................................................................ 5
1.2 Access the ECFthrough FileNet ..................................................................... 6
1.3 Review the Employment Certification Form ..................................................... 7
Section 2: Resources ............................................................................................. 8
2.1 All Governmental Organizations ..................................................................... 8
2.2 Tribal Organizations ...................................................................................... 9
2.3 Tax Exempt/501(c)(3) Organizations ............................................................ 10
2.4 Private Not-For-Profit Organizations ............................................................. 11
2.5 Qualifying Public Services ............................................................................ 12
2.6 Determining if Charter Schools are Not-For-Profit .......................................... 13
2.7 Private Not-For-Profit Health-related Reviews................................................ 14
2.8 Handling Conflicting/Erroneous Information .................................................. 15
Section 3: Taking Action on ECF ........................................................................ 15
3.1 Approve Employer....................................................................................... 15
3.2 Deny Employer ........................................................................................... 16
3.3 Return Record to Supervisor ........................................................................ 16
3 .4 Refer ECFto FSA........................................................................................ 17
3.5 PSLFEmployer Retractions .......................................................................... 18
Section 4: Additional lnformation ....................................................................... 21
4.1 Alternative Certification ............................................................................... 21
4.2 Employer No Longer Exists or Employer Refusing to Certify ............................ 22
Related Documents .............................................................................................. 23
Related Letters ..................................................................................................... 23
Related Technologies/Reports ............................................................................ 23
Employment Certification Form Review Manual

Proprietary & Canf1dentiaf
EMPLOYMENT CERTIFICATION FORM REVIEW MANUAL
Screens................................................................................................................. 23
Work Queues/Action Request Codes (ARCs) ............................................................ 23
00~ .................................................................................................................... ~
Appendix A ............................................................................................................. 25
A.1 Accessing COMPASS5 M •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 25
Appendix B ............................................................................................................. 25
B.1 Saving Documentation in Compliance Drive .................................................. 25
Appendix C: Employment Certification Form .................................................... 27
Resources/Authority ............................................................................................ 32
Employment Certification Form Review Manual

Proprietary & Confidential
VERSION PURPOSE/CHANGE AUTHOR/ REVIEWER DATE
1.0 Initial Draft Kim Myers 3/6/2013

1.1 Approved Kim Myers 1/22/2015
2.0 Updating Format and Flow Theresa Helwig 7/7/2016
2.1 Provided additional comments/sunnestions Kim Mvers 7/11/2016
2.2 Provided clarification Kim Myers 08/02/2016
2.3 Published Theresa Helwig 01/03/2017
3.0 • Added new section: PSLFEmployer Retractions Theresa Helwig
• Reviewed
• Published Kim Myers
Theresa Helwia 04/27/2017
Summary
The purpose of this document is to provide general processes and resources for designated Compliance employees to
use when conducting Employment Certification Form reviews.
There may be instances where even after researching the employer you are still unsure if you can approve. In these
instances, these casesshould be reviewed with the Senior Compliance Coordinator/Compliance Manager.
Acronyms
BU Business Unit
DBA Doing Business As
EDGAR Electronic Data Gathering Analysis and Retrieval system
Employer Identification Number: An Employer Identification Number (EIN) is also

EIN known as a Federal Tax Identification Number, and is used to identify a business
entity. Generally, businesses need an EIN.

Proprietary & Conf1d!"nlial Page I3
EMMA Electronic Municipal Market Access
PHEAA Pennsylvania Higher Education Assistance Agency
RACF Resource Access Control Facility
SEC Securities and Exchange Commission
soc Standard Occupation Classification
Foundational Material
The Business Unit (BU) performs the initial review of all Public Service Loan Forgiveness (PSLF) Employment
Certification Forms (ECFs) received by Fedloan Servicing (FLS). If the employer is private not-for-profit, a
charter school, the BU determines an employer does not qualify, or if the BU cannot determine whether the
employer qualifies, the ECF is escalated to Compliance. The BU must also escalate the ECFto Compliance if
Compliance previously approved the employer more than 12 months in the past.
Only employers that are escalated by the BU should be reviewed by Compliance. If the employer was
previously approved or denied within the past 12 months, it should be returned to the BU with a comment.
All reviews should be conducted based on the specific box checked on the ECF. However, when researching, it
may be determined that the employer actually falls under another category. All categories should be
reviewed for eligibility prior to denying the request.
All prior ECFsshould be reviewed to ensure no approval or denial errors were made previously. Also be aware
that several ECFsmay be in one image, so it is important to scroll through the entire imaged document to
locate the correct ECFthat requires review.
It is important to save any evidence found during research regarding the qualifying status of the employer.
See Appendix B for instructions on saving information to the appropriate folder.

Section 1: PSLF Employer Database

1.1 Locate Escalated Employer
1) Access the PSLF Database (Employer Database) by clicking on the shortcut to open WAPC
Launchpad.
2) Select PROCESSINGTOOLS, and then PSLF ORG DATABASE
a) See your supervisor for the link path to the database
3) Select PUB SERVICEORG UNDER REVIEW-COMPLIANCE tab to access escalated employers for
Compliance review
a) To view specific information about the employer, including representative comments, select
the VIEW DETAIL button.
b) The following details are displayed:
i} PH or P # of the processing individual
ii) ECFStatus (pending, hold, completed)
iii) Date ECF Completed
iv) SSN of the borrower
v) Name of the employer (listed as Pub Service Org)
vi) Website of the employer
vii} EINof the employer
viii) City of the employer
ix) State of the employer
x) Type of Organization (government, not-for-profit, AmeriCorps, private not-for-profit, Peace

Corps)
xi) Type Not-For-Profit (public safety, law enforcement, public interest legal services, early
childhood education, individual with disabilities/elderly, public health, public education,
public library services, school library services, other school based services, emergency
management)
xii) Date Entered
xiii)Reviewer
xiv)lnconclusive Type (W2 needed, Paystubs needed, proof of not-for-profit status needed,
proof of qualifying public service needed, articles of incorporation needed, letter from
employer needed, other)
xv) Status (approved, approved religious, denied, inconclusive, under review)
xvi)Denial Reason

xvii) Date approved/denied
xviii) Comment history
xix) New comment
c) To leave the record about an employer and to access another employer, select CANCEL
4) If not already added, add the escalated employers to the ECFREVIEWStab of the Compliance
spreadsheet (ECF Reviews 2012-2016) saved to compliance$ (\\a net) (J:)\FedLoan
Servicing\!A_FLS Compliance Team
1.2 Access the ECF through FileNet
*
1) From the Employer Database details screen, capture the borrower's SSN
NOTE: The oldest open employer entry with Compliance should be worked first.
2) Using Internet Explorer, go to

l(b)(5)
3) Log in using your HERA P/PH# and password
4) Enter the SSN into the "Account Number or SSN" field
5) Press Enter
6) Access the "FLS Servicing library" by selecting VIEW LIST (if multiple libraries appear)
7) Select the most recent PSECFtask, identified under the column "Action Request Code," by
selecting VIEW DOCUMENT
i;?;NOTE: If t~ere is not a PSECFtask, check other Action Request Codes (ARCs) since an ECFcan
be logged incorrectly.
a) Use the arrows at the bottom of File Net to page through the document until you get to the
page that contains the Employment Information section of the ECF
b) If the document you selected does not coincide with the escalated employer, close the
document and select the next most recent ECF
i) Select SEARCHRESULTSfrom the top of the FileNet page
ii) Select VIEW DOCUMENT of the next most recent ECF
8) Save the ECFdocumentation in the Compliance Drive
a) See Appendix B for further instructions
9) Determine if employer was previously approved/denied
a) Review the Compliance spreadsheet
i) Press your CTRLand F key simultaneously
ii) Type the name of the employer or EIN in the FIND WHAT field

iii) Select FIND ALL
iv) Review identified records to determine if employer was previously approved/denied
b) If employer was previously approved/denied within the last 12 months, return the ECFto the
BU Supervisor
i) Proceed to Section 3.3 to return the record
c) If employer was not previously reviewed, proceed to Section 1.3
1.3 Review the Employment Certification Form

1) Review the ECFto ensure the borrower is not also the certifying official
a) If borrower is the certifying official, return the record to the BU to contact borrower to have
another individual authorize the form
i) See Section 3.3 to return record
2) Take note of the employer's name, EIN, address and which type of public service organization box
was selected. This information will be needed when researching employer.
U NOTE:Some employers provide the DOING BUSINESSAS (d/b/a) name, so further research,
such as checking employer's website, may be needed to determine official name
3) Review the ECFfor any additional pages or stray comments made by the employer or borrower
a) If any pertinent information (EIN, address, etc.) is missing from the ECF,review COMPASS5 M
(ITL2U, ITD2A),
i) See Appendix A for instructions on accessing/reviewing COMPASSsM, or FileNet {PSCOM)

as appropriate to ensure the BU attempted to obtain the missing information.
ii) If BU did not obtain the missing information, return the record to the BU Supervisor
through the database to obtain the missing information
(1) See Section 3.3 to return record
4) Save the ECFand any pertinent information
i) See Appendix B for further instructions.

Section 2: Resources
Listed below are the resources that should be used to thoroughly research employer eligibility for PSLF.The resources
are organized by the options listed on the ECF.These resources, paired with training, assist in accurately identifying
which employers will be approved or denied.
2.1 All Governmental Organizations
Government organizations include Federal, state, local, or Tribal government organizations, agencies,
or entities; public child or family service agency; a Tribal college or university; or the Peace Corps or
AmeriCorps. This does not include a member of the U.S. Congress, as they are not eligible; however,
congressional staffers are eligible. Also, tribal casinos do not automatically qualify.
According to regulations, governmental organizations automatically qualify for PSLF.Therefore, the

type of public service does not need to be verified. The only exceptions are tribal organizations. See
Section 2.2 for additional steps that need to be taken to verify if a tribal organization can be approved
for PSLF.
• Employer Identification Number (EIN) Validation Website:

o After entering in the EIN, a banner will appear either confirming or denying whether the EIN is
valid.
• GuideStar: The world's largest source of information on not-for-profit organizations.

o Sign-in or create a free account (click on Create Account), if you haven't already done so.
TIP: Search the employer by the EIN and by the name in case the employer/borrower made a
typo on their EIN. If the employer made a small mistake by switching two numbers, update
the EIN in the database and process accordingly.
o Review the employer's GuideStar record, if found, for language indicating the employer is
government. If so, the employer can be approved (Section 3.1).
■ Ex. This organization is not required to file an annual return with the IRS because it is an
arm of a state or local government.
* NOTE: Government Organizations will not typically have filed an IRS Form 990 1 . This is
one way to verify that an organization is in fact associated with the government.
• EMMA (Electronic Municipal Market Access): EMMA provides documents and data derived from a
number of sources.
o Use the "Quick Search" function in the upper right hand corner of the homepage to search the
name of the organization. Variations of the name may need to be tested if the organization
includes an abbreviation.
1 An IRS Form 990 is a Return of Organization Exempt From Income Tax form. This form is used by tax-exempt
organ1zat1onsand nonexempt charitable trusts.

o Review the ISSUERNAME column for the employer in question. The employer can be approved
if they are listed as an issuer (Section 3.1).
~ TIP: You may need to try different variations of the employer name
C· If no results are displayed, the organization most likely does not issue bonds.
• Google EIN:
~ TIP: Format the Google search with the word "EIN" followed by the actual EIN using the
hyphen (Ex. EIN 12-3456789).
C· Review results to determine if the EIN is tied to the government. If results specifically show
that EIN is tied to a governmental agency, the organization can be approved (Section 3.1).
C· Results may show that the EIN is listed on another organization's Form 990. Review other
organization's Form 990 Schedules I and R to determine the type of entity listed for the
employer's EIN.
NOTE: Research may indicate that an EIN provided on an ECFbelongs to another
* organization. Compliance needs to determine if there is a link between the

organizations. If the link cannot be determined, return the record to the BU to request
W-2s (Section 3.3).
• Google for employer website if not included on the ECF:

o If the domain is .gov or .mil, the agency can be approved (Section 3.1).
C· If the employer is a public school, not including charter schools, the organization can be
approved. For charter schools, see Section 2.6.
o If domain is not .gov or .mil, search state and/or local government websites. If listed on a
government website, determine if employer is actually part of the government, or the
*
government website is simply providing a list of entities, such as licensed day care providers.
NOTE: Being listed on a government website does not mean that the employer is a
government entity
• Google for financial statements:

C· In the search box, type in the employer name followed by "Financial Statements." If located,
review the financial statements for any language indicating the employer is governmental
(e.g., political subdivision, body politic, etc.). The employer can be approved , if acceptable
language exists (Section 3.1}.
C· If the financial statements indicate that the employer participates in the state's retirement
program, the organization is a government agency and can be approved (Section 3.1}.
2.2 Tribal Organizations
It is important to determine the relationship between a tribe and a tribal casino.
• System for Award Management Website: An official website of the U.S. government that
combines federal procurement systems and the Catalog of Federal Domestic Assistance into one
system.

o This website should be used to determine if a casino is regarded as a distinct entity from the
tribe itself.
o On the homepage of the website, select "Search Results" from the last column titled "Search
Records. Use the "Quick Search" function in the upper right hand corner of the homepage to
search the name of the organization. Variations of the name may need to be tested if the
organization includes an abbreviation.
o If the casino is a tribal 8{a) organization under the Small Business Administration's parlance 13
CFR 124.109(c)(2), the entity is not a qualifying employer for PSLF(Section 3.2).
o If no results are displayed, the organization is most likely not a tribal 8(a} organization.
• Google casino:
o Google the casino to determine if it is owned and operated by the tribe or if they have
sovereign immunity 2 . Also, look for their by-laws or constitution to make a determination for
qualification.
2.3 Tax Exempt/501(c)(3) Organizations
• GuideStar: The world's largest source of information on not-for-profit organizations.
TIP: Search the employer by the EIN and by the name in case the employer/borrower made a
typo on their EIN. If the employer made a small mistake by switching two numbers, update
the EIN in the database and process accordingly.
o Review the Form 990 to determine the employer's filing status (Item I -Tax-exempt status)
C· If 501(c)(3), employer automatically qualifies but additional review is needed to determine if
agency actually employs paid employees or only accepts volunteers.
■ In Part I of the Form 990, if line 5 is "O" then the organization does not have employees.
Request a W-2 to determine who pays the borrower (Section 3.3).
• Google EIN provided on the ECF:
C· If the Google search brings up a BrightScopc entry, the organization may be for-profit and
should be reviewed further.
C· Review any other pieces of information that result from the EIN search to determine if the
employer can be classified as 501{c)(3).
• IRS Exempt Organizations Select Check tool (former Publication 78): Exempt Organizations Select
Check is an on line search tool that allows users to search for and select an exempt organization
and check certain information about its federal tax status and filings.
o Search in the Exempt Organization Select Check Tool and select the radio button beside "Are
Eligible to Receive Tax-Deductible Charitable Contributions." If employer appears, review the
column titled Deductibility Status. The employer can be approved (Section 3.1) if "PC" is listed.
2 Tribal Nations are given sovereign immunity, which prohibits suit against a Tribe unless it has waived its immunity, has
consented to be sued, or Congress has expressly retracted the immunity.

o If any other status is listed, they are not-for-profit, but must be reviewed to determine if the
employer performs a qualifying public service (Section 2.5).
o If the employer does not appear, return to the Exempt Organization Select Check Tool and
select the corresponding radio buttons to search if the employer was automatically revoked or
filed a Form 990-N (e-postcard). If the employer appears under the search for being
automatically revoked, review the date listed in the Revocation Date column. Any certified
employment prior to this date can be approved (Section 3.1}.
• IRS Business Master File (BMF}: The Exempt Organization Business Master File Extract {EO BMF)
includes cumulative information on exempt organizations. The data are extracted monthly and are
available by state and region.
C· Search by selecting the state where the employer's corporate office is located. Review the
Subsection Code (Column I) in the spreadsheet that coincides with the employer. The
employer can be approved if Subsection Code (Column I) is 3 (Section 3.1).
o The employer should be reviewed as private not-for-profit (Section 2.4) if the subsection code
(Column I) is something other than 3 and the entity is NOT a religious entity. If subsection code
(Column I) is something other than 3 and the entity IS clearly a religious entity, the employer
*
may be approved.
NOTE:Religious entities may self-certify as a 501(c}(3) organization, and therefore may

not be listed in IRS Exempt Organizations Select Check or IRS BMF even though the
employer qualifies.
• Review the employer's website:

C· If employer is wholly owned by another organization (e.g., a hospital that is owned by a larger
organization}, search the above resources using the name of the parent organization and/or
EIN. If parent organization is not found, the organization must be reviewed to determine if
they are Private Not-For-Profit. If parent organization is found, search the entity on GuideStar:
■ Review the Form 990 Schedule H, Section A to determine if the employer is a Hospital
Facility of the parent organization. If employer is found here and the parent organization is
501(c)(3), the employer may be approved (Section 3.1).
■ Review the Form 990 Schedule R, Part 1 Identification of Disregarded Entities to determine
if the employer is a Disregarded Entity. If employer is found here and the parent
organization is 501(c)(3), the employer may be approved (Section 3.1).
2.4 Private Not-For-Profit Organizations
• SEC/EDGAR(Electronic Data Gathering, Analysis, and Retrieval system): EDGAR performs

automated collection, validation, indexing, acceptance, and forwarding of submissions by
companies and others who are required by law to file forms with the U.S. Securities and Exchange
Commission (SEC).Anyone can access and download this information for free.
o Use the Company Filings Search to search for the employer under Company Name. If the
organization is found, the company is a for-profit business and should be denied {Section 3.2).

Proprietary & Conf1d!"n,lial Page I 11
• State Corporation Bureau or Secretary of State website (for the state of the employer): A compiled
list of links for legal professionals and others who are looking for quick access to the corporate
information available in on line searchable databases maintained by the Secretary of State for any
given state.
C· Search for the state in which the corporate office is located. If search provides corporation
status (not-for-profit, for-profit, etc.) and employer is listed as not-for-profit, the organization
should be reviewed for qualifying public service in Section 2.5. Any employer listed as for-
profit should be denied (Section 3.2).
• If the business filing indicates that organization owns stock, this is typically an indication
that the organization is for-profit and should be further reviewed.
• Review the employer's website:

o If the website provides no indication of not-for-profit status or qualifying public service, the
employer must provide additional information to verify not-for-profit or qualifying public
service status.
o If the website indicates that the employer is not-for-profit, but no other verification of not-for-
profit status is found, the employer should be escalated to FSA (Section 3.4).
o If the website indicates that the employer is not-for-profit and verification is found, the
employer should be reviewed for qualifying public service in Section 2.5.
• Skilled Nursing Facility Directory (nursing homes): This nursing home directory contains over
*
15,600 skilled nursing facilities in the United States.
NOTE: This resource should be used as a last resort if no conclusive information can be
found.
o Perform a search using the zip code and select the appropriate nursing home to review the
Ownership Type. If the Ownership Type is eligible, the organization can be approved (Section
lil
o See Section 2.7 for more information related to determining if Private Not-For-Profit health
institutions qualify as performing a public service.
2.5 Qualifying Public Services

• Employer must perform one of the following public services to qualify:
o Emergency management
o Military service
o Public safety
o Law enforcement
o Public interest legal services: Refers to legal services provided by a public service organization
that are funded in whole or in part by a local, State, Federal, or Tribal government
C· Early childhood education: Including licensed or regulated child care, Head Start, and State
funded pre-kindergarten
C· Public service for individuals with disabilities
o Public service for the elderly

o Public health: Includes nurses, nurse practitioners, nurses in a clinical setting, and full-time
professionals engaged in health care practitioner occupations and health care support
occupations, such as those defined by the Bureau of Labor Statistics
C· Public education: Includes services that provide educational enrichment or support directly to
students or their families in a school or school-like setting
C· Public library services
o School library services
C· Other school-based services
~·'-7 NOTE: Some not-for-profit employers may seem like they should qualify; however, FSA
M
determined that they do not qualify .. These employers include: credit unions, social
workers, and most associations.
• State Corporation Bureau or Secretary of State website (for the state of the employer): A compiled
list of links for legal professionals and others who are looking for quick access to the corporate
information available in on line searchable databases maintained by the Secretary of State for any
given state.
o Review the Articles of Incorporation, if available, under the agency's business filing to
determine which type of public service the organization provides.
• Google website: In order to determine if confirmed not-for-profit performs a qualifying public

service.
C· If no match (account for acronyms, abbreviations, etc.), review name of employer and
determine if you strongly feel they may provide a qualifying public service or if it appears the
ECFmay escalate and result in multiple denials. If name of employer leads you to think they
may provide a qualifying public service (e.g., medical facility, school, etc.), or the ECFhas the
potential to escalate, return the record through the database to contact employer for more
information (Section 3.3).
C· If name of employer leads you to think they do not provide a qualifying public service (e.g.
staffing agency} and there's no reason for the ECFto escalate, deny for the reason we could
find no evidence they perform a qualifying public service (Section 3.2).
o If a match is found and the website clearly indicates that employer provides a qualifying public
service, the organization can be approved (Section 3.1).
o If a match is found and the website indicates that the employer does not provide a qualifying
public service, the organization can be denied (Section 3.2).
o If you cannot determine if employer performs qualifying public service, deny with a request for
evidence of what types of qualifying public service they perform (Section 3.2).
2.6 Determining if Charter Schools are Not-For-Profit
NOTE: Charter schools in Hawaii and Massachusetts are automatically classified as government
and will not be managed by another entity. Charter schools in these states can be
automatically approved as government.

• Review charter school's website: Charter schools can be run by a managing entity, which can be
for-profit, depending on the state in which the charter school is established. In particular, the
employees of charter schools managed by the Leona Group are actually employed/paid by the
Leona Group, which is a for-profit entity.
C· If the website research shows that the charter school is managed by another entity, return the
record to request more information from the BU {Section 3.3).
C· If the charter school is not managed by another entity, process the ECFbased on the EIN
provided on the form.
C· If the EIN belongs to another entity, review the eligibility of the entity that holds the ElN. If the
entity that holds the EIN is solely a payroll processing company (ex. ADP, PEO), the charter
school itself should be reviewed for eligibility and not the payroll processing company.
o If the entity that holds the ElN is not related to the charter school, return the record to the BU
supervisor to request the borrower's W-2 or a copy of the borrower's paystub (Section 3.3).
• Take note if the EIN provided on the form belongs to the charter school itself or to another entity,
as this may signify they are managed by another organization.
2.7 Private Not-For-Profit Health-related Reviews
Health-related organizations include social work organizations and health/dental plans.
NOTE:You may not be able to determine if certain organizations perform a qualifying public
service (e.g., organizations for certain groups of individuals). In these instances you must
review the employer to see if they employ individuals that meet the criteria for certain
Standard Occupation Classification (SOC) codes.
• Review Open Job Positions (search for careers on employer's website):

o Review to see if the employer has a posted position for an individual that would meet the
criteria for Standard Occupation Classification (SOC)codes for 29-0000 or 31-0000.
• The 2010 Standard Occupational classification System (Bureau of Labor Statistics): The 2010
Standard Occupational Classification (SOC)system is used by Federal statistical agencies to classify
workers into occupational categories for the purpose of collecting, calculating, or disseminating
data.
o Review the job categories under "29-0000 Healthcare Practitioners and Technical
Occupations" and "31-0000 Healthcare Support Occupations." If any open position at the
organization is performing the service of a job category found under 29-0000 or 31-0000, the
employer qualifies and can be approved {Section 3.1).
TIP: If you are unsure if an open position meets the criteria for a job category in the
SOC, review the particular state's definition for the job in question (e.g., nursing) in
conjunction with the job posting to determine if the employer qualifies. The state's
definitions can be found by searching the state's statutes.
o If significant uncertainty remains, escalate the employer to FSA (Section 3.4).

2.8 Handling Conflicting/Erroneous Information
• If any of the following scenarios are encountered, return the record to the BU supervisor, outline
the reason the record is returned, and/or request the borrower's W-2 or a copy of the borrower's
paystub (Section 3.3).
o EIN that does not coincide with an EIN identified for the employer through research.
*
NOTE: If the employer/borrower made a small mistake by switching two numbers,
update the EIN in the database and process accordingly.
C· EIN that was identified as belonging to another organization and no relationship between the
organizations can be identified.
o Any other issue that requires more clarification before you can conclusively approve or deny
(e.g., you need to determine where the BU obtained the EIN, there is a notation on a cover
letter that contradicts what is on the ECF,etc.).
Section 3: Taking Action on ECF

This section provides instruction for notifying the BU of the outcome of the escalated ECFfor PSLF.
3.1 Approve Employer

1) Select the specific employer (View Details)
2) Select MAKE EDITS
*
a) Use the drop down selections for TYPEOF ORG to select the appropriate type of organization
NOTE: If you determine an employer falls into multiple categories -with

of AmeriCorps and Peace Corps, as they should always be approved under their
the exception
respective category- always choose the category according to hierarchy (government

first, not-for-profit second, and private not-for-profit third). For example, if you
determine an employer is government and not-for-profit, you should approve them
under government.
i} Gov Org- For Government
ii) Not-For-Profit- For 501(C){3)
iii) Private Not-For-Profit- For Not-For-Profits That Are Not 501(C)(3)
iv) AmeriCorps
v) Peace Corps
b) Use the drop down selections for TYPE NON-PROFITto select the appropriate type of not-for-
profit qualifying service (only used when Private Non-For-Profit from step immediately above
is selected)
i) Emergency Management

Proprietary & Conf,ct!"nlial Page I 15
ii) Military Service
iii) Public Safety
iv) Law Enforcement
v) Public Interest Law Services
vi) Early Childhood Education
vii) Individuals with Disabilities/Elderly
viii)Public Health
ix) Public Education
x) Public Library Services
xi) School Library Services
xii) Other School Based Services
c) Use the drop down box beside Status and select 'Approved'
i) Enter a comment in the comment box stating why the employer was approved, followed
by your initials. Comment typically just restates the type of employer, e.g., Employer is
private not-for-profit providing public education. DF
ii) Select SAVE
3.2 Deny Employer

a) Use the drop down box beside Status and select DENIED
i) Enter a comment in the comment box stating why the employer was denied, followed by
your initials, e.g., Employer is for profit. DF; Employer is private not-for-profit, but doesn't
provide a qualifying public service. OF
ii) Select SAVE
3.3 Return Record to Supervisor

a) Use the drop down box beside Reviewer and select SUPERVISOR
i) Enter a comment in the comment box stating why the record is being returned, followed
by your initials, e.g., We are unable to tie EIN on ECFto employer. Please contact borrower
for a copy of their W-2. OF
ii) Select SAVE

3.4 Refer ECF to FSA

1) Draft email to FSA outlining questions
a) WinZip and password protect any attachments, including the ECF, needed for the e-mail
5
Access em lo er folder previously created i,L(b_l(
_I______________ ~
i)
b)(5)
Reviewed that contains all documents to be sent to FSA
ii) Right click on main folder

iii) Select WINZIP
iv) Add to Zip File
v) Make selection under options ENCRYPTADDED FILES
vi) Click ADD
vii} Select OK from caution window pop-up

viii) Enter passwor bl(5l
~------------------~
ix) Reenter password
x) Click OK
xi) Close window
b) Attach WinZip file to e-mail (Note: Password must be forwarded in a separate e-mail)
c) Send e-mail to ~(b_l(_51
______ ~{place "employer name" in subject line)
2) Send password to (bl(5l in separate e-mail (place "PW employer name" in subject
line)
3) Move employer to FSA review in Employer Database
a) Select the specific employer (View Details)
b) Select MAKE EDITS
i} Use the drop down box beside Reviewer and select FSA
ii) Enter a comment in the comment box stating that the employer was referred to FSA,
followed by your initials.
iii) Select SAVE
4) Update ECF Reviews 2012-2016 spreadsheet with outcome of review and save

3.5 PSLF Employer Retractions
Effective November 15, 2016, any PSLFEmployer decision that should be retracted must be escalated
to FSA for review. The BU will forward an email containing the applicable employers to be retracted
and all effected ECFsto the Fedloan PSLFMailbox. The following process should be used by
Compliance to escalate the retractions to FSA.
1} Once several retractions are received from the BU, create a folder in
l(b)(5)
a) Name the new folder (bl(5l

~------------------~
i) Ex: If the retractions are sent on April 19, 2017, the name of the folder would be "Employer
Retractions 2017.04.19"
2} Create a new Excel spreadsheet with the same name as the folder
3} Include four columns on the spreadsheet titled:
a) Employer
b) Number of Borrowers Impacted
c) Date of Oldest Approval
d) Reason for Retraction
4) Using the information provided in the BU's email, fill in the following columns on the spreadsheet
appropriately
a) Employer
b) Number of Borrowers Impacted
c) Date of Oldest Approval
"tr NOTE:List the Employers in alphabetical order

=~-----------,
5
5) Open the internal employer spreadsheet located in (bl( l
Compliance Team
6) Review the internal employer spreadsheet to determine the reason for the retraction.
a) Ex: the employer is for-profit; the employer is not-for-profit and not providing a qualifying
public service; etc.
7) Add the reason for the retraction to applicable column in the newly created spreadsheet.
8) Access the employer files for the retracted employers

a) Go to (\\ANET)(J:)\Fedloan Servicing\PSLF\ECFs Reviewed
b) Locate the applicable employer files

i) Select the appropriate employer folder
ii) Right Click on the folder

iii) Select Copy
c) Return to the Employer Retractions_yyyy.mm.dd folder
i) Right click in the folder
ii) Select Paste
d) Review the contents of the employer folders that were copied over
i) Remove any unnecessary ECFsthat are in the folder
9) Copy the ECFsfrom the business unit's original email and paste them in the respective employer's
folders that were copied over in the previous step.
51
10) Once the spreadsheet is complete and the~(b_l(_____________ ~older contains all
of the necessary information, winzip the folder.
a) Right click on the file and find WinZip
i) An additional menu of options will appear, select ADD TO ZIP FILE
b) On the screen that appears, select ENCRYPTADDED FILES(under Options)
c) Select ADD
d) Create a password using PSLF_month_day
i) Ex: PSLF_Apr_l9
e) Re-enter password
f) Select OK
11) Send an email to ~-------~
(b)(5J from the FedLoan PSLFemail box
a) Include the zipped folder in the email
12) Send a separate email to L(b_l(_51

______ ~ from the Fedloan PSLFemail box
a) Include the password for the zipped folder
13) Move the email that was received from the business unit in the FedLoan PSLFMailbox to the
"Retractions" folder until a response is received from FSA
14) Act on guidance from FSAwhen they respond
a) Respond to the email from the BU located in the "Retractions" folder with the guidance
provided by FSA
b) If FSA requests the retraction letter
i) Inform the BU of their request and monitor the mailbox for the retraction letter
ii) Once the letter is received,
*
(1) Make any necessary edits
NOTE: Ensure the file name includes the name of the employer

iii) Create a new folder in bJ(5l

~------------------------
( 1) Name the folder the employer's name
iv) Save the retraction letter to the newly created folder
v) Winzip the folder named after the employer
(1) Right click on the file and find WinZip
(a) An additional menu of options will appear, select ADD TO ZIP FILE
(2) On the screen that appears, select ENCRYPTADDED FILEs(under Options)
(3) Select ADD

. l(b)(5)
(4) Create a password using
(a)
rb)(5)
•
i
(5) Re-enter password
(6) Select OK
(bl(5l
vi) Send an email to ~-------~ from the FedLoan PSLFemail box
(1) Include the zipped folder in the email

(bl(5l
vii) Send a separate email to ~-------~ from the FedLoan PSLFemail box
(1) Include the password for the zipped folder
viii)Move the email with the retraction letter that was received from the BU to the "Letters
Sent to FSA" folder in the FedLoan PSLFmailbox
c) If FSA does not request a retraction letter

5
i) Creatf a folder in tbJbl( l
. I d bl(5l r, . h d
tit e ~-----------rs1ng t e current ate
ii) Copy and paste the letters provided by the BU into the newly created folder
iii) Winzip the folder
(1) Right click on the file and find WinZip
(a) An additional menu of options will appear, select ADD TO ZIP FILE
(2) On the screen that appears, select ENCRYPTADDED FILES(Under Options)
(3) Select ADD

(4) Create a password usingl(bl(5l
(a) ~(b)(51 I ~------
(5) Re-enter password
(6) Select OK

ii) Send an email to (bJ(5J from the FedLoan PSLFemail box

~-------~
(1) Include the zipped folder in the email
iii) Send a separate email to 5 1______
L(b~l(_ ~from the FedLoan PSLFemail box
(1) Include the password for the zipped folder
Section 4: Additional Information

4.1 Alternative Certification
1) If an exception occurs and the borrower provides alternative certification, review it for required
information
a) Certification must contain
i) Name of employer
ii) EIN of employer
iii) Address of employer
iv) Full-time/part-time status of borrower/employee
v) Dates of employment of borrower/employee
vi) Signature and date of authorized official of the borrower's employer
vii) Contact information for the authorized official
b) If alternative certification does not contain all of the required pieces (except for
signature/ date/ contact information),
i) Return record to BU to contact employer for missing information
(1) See Section 3.3
c) If alternative certification does not contain signature/date/contact information for authorized

official,
i) Return to BU Supervisor as a denial
*
(1) See Section 3.3
NOTE:This is returned to the BU Supervisor solely to point out that the

documentation should never have been escalated to Compliance since required
information was missing.
2) If all required information is present, follow steps on reviewing employer
a) See Section 2

4.2 Employer No Longer Exists or Employer Refusing to Certify

1) If borrower checks the box on ECFindicating he/she is unable to obtain certification because the
organization no longer exists or the organization refused to certify, follow steps on reviewing
employer (see Section 2) to determine if employer qualifies
2) Review the documentation of pay. (refer to docu
4
e □t nrovided bv FSA Sl! □ Portine
.
documentat1on-dra f t021612 f ound at comp I'1ance (b)( 5 )
l(b)(5) I
3) If the documentation of pay is not provided, return to the BU to request the borrower provide
documentation of income.
a) See Section 3.3
NOTE: A W-2 is required, and paystubs are encouraged, but optional.

Related Documents
(b)(5)
ECF Reviews 2012-
2016
FSA Supporting (b)(5)

Documentation -
Employer No Longer
Exists
I
(b)(5)
PSLF Q&A Document
Related Letters
Not Applicable
Screens
Screen Name System Mode Description
TDZA COMPASS SM I Activity Display
TLZU COMPASS SM I Public Service Loan Forgiveness Screen
Name Code Description
PSCOM Not Applicable Public Service Loan Forgiveness Comment
PSECF Not Applicable Public Service Loan Forgiveness ECF

Other
Name Description
System used to review account level data. Accessed by using the

COMPASSSM
HERA session link on the desktop.
h tt12:LLwww. hi 12a comLM ed icaI Data Val id ati onL Em12I

as12ace. Oy'er Id
EIN Validation Website
cntification NumbcrLEIN Validation.as12x
Electronic Municipal Market Access

:LL
httr::1 em ma. msrb .orgLSearchLSearch .asQ:X
(EMMA) Website
Employer Database Access database used to house escalated employer reviews
File Net Repository of imaged documents
GuideStar htt12:LLwww .gu idesta r.orgL
http://www. i rs .gov /Ch a rities-&-N on- Profits/Exempt-Organizations-

IRS Business Master File (BMF)
Business-Master- File-Extract-EO-B MF
IRS Exempt Organizations Select h tt12:LLwww. i rs .gov [Ch a rities-&-N o n-ProfitsLExe m 12t-Organizations-
Check tool {former Publication 78) Select-Check
SEC/EDGAR (Electronic Data h tt12:l[www.sec.gov Ledgar. shtm I

Gathering, Analysis, and Retrieval
system)
Skilled Nursing Facilities Website httQ:l[www.skillednursingfacilitics.org[dircctor'iL
State Corporation Bureau or httr::1:LLwww.coordinatedlegal.com[Secretar'iOfState.html

Secretary of State website
httQs :l[www.sam.gov Lr::1ortalLSAML?r::10

rta I:com r::1on
e ntl d= 3 lbe 779b-
ffb 7-4907-b 7bl-
System for Award Management
e 7 4a85af25d6&i nteracti onstate= J BPNS rOOABXcOABBfa n Nm QnJ QZ
Website
Gd IVm IldOIkAAAAAQA TL2QzZi9 mdWS j dGlvb m FslmQzcAAH X 19 FTOZf
Xw* * &r::1ortal:t1£12e=action#1#1
The 2010 Standard Occupational httpJ /www.bls.gov/soc/

classification System

Appendix A
A.1 Accessing COMPASS''•'
1) Open the shortcut to the HERAsystem located on your desktop
2) Type PHEM, press enter

3) Enter your username (ph/p #) and RACF password, press enter
4) Clear your screen by pressing your 'Pause/Break' key
5} Set up your bridge key, if you haven't done so already
a) From a clear screen type 'PFCH' and press Enter
b) Beside the key you would prefer as your bridge key, type 'TX3Z'
c) Press Enter
6} From a clear screen, type the screen you want to access {ITL2U, ITD2A, etc) followed by the SSN
and press Fl.
Appendix B
B.1 Saving Documentation in Compliance Drive
1) From FileNet (for ECF),website and/or resource document, select FILE,then PRINT
2) Select CUTEPDFWRITER, for Acrobat Reader or ADOBE PDF if you have Adobe Acrobat Pro
a) If you do not have either, contact the Help Desk for instructions on how to install CutePDF
Writer
3} Select the page range you want to save
<;\ TIP: If saving a Form 990 from GuideStar, it is usually appropriate to only save the first page
~ and any other pages specifically used; e.g,. Schedule R
4) Select PRINT
5} Once the box pops up, use the drop down arrow and select the compliance$ (\\anet) drive. For
Compliance staff, this is typically the J: drive.
a) Select the FEDLOANSERVICINGsubfolder
b) Select the PSLFsubfolder
c) Select the ECFsREVIEWEDsubfolder
foldE:r I .
r·J1c:,1,
6) Create a subfolder for the employer by selecting the ----~- icon
a) If a subfolder already exists, save the new ECFto the existing folder using ECFand the date
received (ex. ECF 2014.12.14)

Proprietary & Conf1d!"n,lial Page I 25
i} The save has been completed
b) If a subfolder does not already exist, proceed to Step 7
7) Name the folder using the name of the employer
8) Press Enter
9) Select the newly created folder
10) Change the File Name as appropriate
11) Press SAVE

12) Repeat steps to save additional information
~ TIP: When saving future information, skip the steps describing how to create an employer
folder since once has already been established.

Appendix C: Employment Certification Form
PUBLIC SERVICE LOAN FORGIVENESS (PSLF): 0MB No. 1845-0110

Form Approved
EMPLOYMENT CERTIFICATION FORM Exp. Date 12/31/2017
William D. Ford Federal Direct Loan (Direct Loan) Program
WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on
PSLF ECF any accompanying document 1s subject to penalties that may me lude fines. impmonment. or both. under
the U.S. Criminal Code and 20 U.S.C. 1097.
SECTION 1: BORROWER INFORMATION
Please enter or correct the following information.
D Check this box if any of your information has changed.
SSN
Date of Birth
Name
Address
City State Zip Code
-----
Telephone - Prim<1ry
Telephone - Alternate
Email (Optional)
SECTION 2: BORROWER AUTHORIZATIONS, UNDERSTANDINGS, AND CERTIFICATIONS
Before signing, carefully read the entire form. For more information on PSLF,visit StudentAid.gov/publicservice.
I authorize:
1. My employer or other entity having records about the employment that 1sthe bam of my request to make information
from those records available to the U. S Department of Education (the Department) or its agents or contractors.
2. The entity to which I submit this request and its agents to contact me regarding my request or my loans at any cellular
telephone number that I provide now or in the future using automated telephone dialing equipment or artificial or
prerecorded voice or text messages.
I understand that:
1. To qualify for PSLF,I must make 120 qualifying payments on my Direct Loan(s) while employed full-time by a qualifying
employer or employers. Neither the 120 qualifying payments nor the employment have to be consecutive.
2. To qualify for PSLF,I must be employed full-time by a qualifying employer when I apply for and receive PSLF.
3. lfl qualify for forgiveness, only the remaining balance on my Direct Loan(s) will be forgiven.
4. By submitting this form, my student loan(s) held by the Department will be transferred to Fedloan Servicing.
5. The Department may request supplemental documentation substantiating my employment.
6. The Department will notify me 1nwr1t1ng or electronically of the number of qualifying payments I have made while
employed full-time by a qualifying employer and how many more I must make before I am eligible to apply for PSLF.
7. The Department will notify me in writing or electronically if the form that I submit is incomplete, or if it determines that
my employment or payments do not qualify for PSLF.The Department will explain the reason for the determination
and the steps I need to take to correct the form or make qualifying payments.
8. The Department wil I retain this certification form until I submit my application for forgiveness.
I certify that all of the information I have provided on this form and 1nany accompanying document 1strue, complete. and
correct to the best of my knowledge and belief.
n Check this box if you cannot obtain certification from your employer because the organization is closed or because the
organization has refused to certify your employment. The Department will follow up to assist you in getting
documentation of your employment. Complete Section 3, but do not complete Section 4.
Borrower's Signature _____________________ _ Date --------

Page I o/6

Proprietary & Conf,d<"ntial Page I 27
Borrower Name Borrower SSN
SECTION 3: EMPLOYER INFORMATION (TO BE COMPLETED BY THE BORROWEROR EMPLOYER)
1, Employer Name: 10. Is your employer tax-exempt under Section 501 (c)(3)
of the Internal Revenue Code?
D Yes - Skip to Section 4.
2. Federal Employer ldentif1cat1on Number (FEINI D No - Continue to Item 11.
11. Is your employer a not-for-profit organization?

Your employer's EIN may be found on your Wage D Yes - Continue to Item 12.
and Tax Statement (W-2).
D No - Your employer does not qualify.
3. Employer Address: 12. Is your employer a partisan political organization?

D Yes - Your employer does not qualify.
4. Employer Website (if any): D No - Continue to Item 13.
13. ls your employer a labor union?

D Yes - Your employer does not qualify.
5. Employment Begin Date:
D No-Continue to Item 14.
14. Indicate which service or services your employer
6. Employment End Date: provides and then continue to Section 4, if
appropriate:
OR - Emergency management
LI Still Employed Military service {See Section 6)
7. Employment Status: D Full-Time D Part-Time _ Public safety
8. Hours Per Week (Average)

= Law enforcement
Public interest legal services (See Section 6)
Include vacation, leave time, or any leave taken
Early childhood education (See Section 6)
under the Family Medical Leave Act of 1993. lfyour
employer 1sa 501 (c)(3) or a not-for-profit organization,
do not include any hours you spent on religious
= Public service for individuals with disabilities
- Public service for the elderly
Instruction, worship services, or proselytizing.
9. Is your employer a governmental organization?

= Public health (See Section 6)
Public education (See Section 6)
A governmental organization is a Federal, State,
Public library services
local, or Tribal government organization, agency, or
entity, a public child or family service agency, a Tribal
college or university, or the Peace Corps or
= School library services
- Other school-based services
AmeriCorps.
D Yes - Skip to Section 4. - None of the above -your employer does not
qualify.
D No - Continue to Item 10.
SECTION 4: EMPLOYER CERTIFICATION (TO BE COMPLETED BY THE EMPLOYER)

By signing, I certify that the information in Section 3 is true, complete, and correct to the best of my knowledge and belief
and that I am an authorized official (see Section 6) oft he organization named in Section 3. Complete the rest of this Section.
Note: If any of the information is crossed out or altered in Section 3, you must initial those changes.
Authorized Official's Name Authorized Official's Phone
----------
Autho n zed Official's Title Authorized Official's Email
Authorized Official's Signature Date

-------------- --------
Page2 of 6
PRe.aa' Employment Certification Review Manual

SECTION 5: INSTRUCTIONS FOR COMPLETING THE FORM

You may submit information about multiple employers by submitting one copy of Sections 1 and 2 (Page 1), and one copy of
Sections 3 and 4 (Page 2) per employer. When completing this form, type or print using dark ink Enter dates as month-day-
year (mm-dd-yyyy). Use only numbers. Example: March 14, 2016 = 03-14-2016. If any information 1scrossed out or altered in
Section 3, it must be initialed by your employer. For more information about PSLFand how to use this form, visit
(b)(5) Return the completed form to the address shown in Section 7.
AmeriCorps position means a position approved by the Peace Corps position means a full-time assignment
Corporation for National and Community Service under under the Peace Corps Act as provided for under 22 U.S.C.
Section 123 of the National and Community Service Act of 2504.
1990 (42 U.S.C.12573). Public education includes services that provide
An authorized official is an official of a public service educational enrichment or support directly to students or
organization (including AmeriCorps or the Peace Corps) their families in a school or a school-like setting.
who has access to the borrower's employment or service Public Interest legal services refers to legal services
records and is authorized by the public service organization that are funded in whole or in part by a local, State, Federal,
to certify the employment status of the organization's or Tribal government.
employees or former employees, or the service of Public health includes nurses, nurse practitioners,
AmeriCorps or Peace Corps volunteers. nurses in a clinical setting, and full-time professionals
Eligible loans are loans that are not in default and made engaged in hcJ th cJrc practitioner occupJtions and hcJ th
under the William D. Ford Federal Direct Loan (Direct Loan) support orrnpat1om, as such terms are defined by the
Program. Bureau of Labor Statistics.
Early childhood education includes licensed or A public service organization is a private not-for-profit
regulated child care, Head Start, and State funded pre- organization that is not a labor union or a partisan political
kindergarten. organization and that provides at least one of the following
An employee means an individual who is hired and paid public services: ( 1} emergency management. (2) military
by the organization. service, (3) public safety, (4) law enforcement, (5) public
Full-time means working in qualifying employment in interest legal services, (6) early childhood education, (7)
one or more jobs for the greater of: (1) An annual average of public service for individuals with disabilities and the
at least 30 hours per week or. for a contractual or elderly, (8) public health, (9) public education, (1 OJpublic
employment period of at least 8 months, an average of 30 library services, (11) school library services, or (12) other
hours per week; or (2) Unless the qualifying employment is school-based services.
with two or more employers, the number of hours the Qualifying payments are separate, on-time, full monthly
employer considers full time. payments made on a Direct Loan after October 1, 2007
Government includes a Federal, State, local or Tribal under a qualifying repayment plan.
government organization. agency or entity; a public child or Qualifying employment includes employment by the
family service agency; or a Tribal college or university. government, employment by a not-for-profit organization
An on-time payment is a payment made no more than that is tax-exempt under Section 501 (c)(3) of the Internal
15 days after the due date for the payment. Revenue Code, AmeriCorps position, a Peace Corps position,
law enforcement means service performed by an or employment at a public service organization.
employee of a public service organization that is publicly Qualifying repayment plans include the Revised Pay As
funded and whose principal activities pertain to crime You Earn (REPAYE}plan, the Pay As You Earn (PAYE) plan,
prevention, control or reduction of crime, or the the Income-Based Repayment (IBR)plan, the Income-
enforcement of criminal law. Contingent Repayment (ICR)plan, the 10-Year Standard
Military service means service on behalf of the U.S. Repayment plsn (Standard Repayment plan with a
Armed Forces or the National Guard performed by an maximum 10-year repayment period), and any other Direct
employee of a public service organization. Loan repayment plan, but only 1fpayments are at least equal
to the monthly payment amount that would be required
under the Standard Repayment plan with a 10-year
repayment period.
Page 3 of6
PRe.aa~ Employment Certification Review Manual

SECTION7: WHERETO SENDTHE COMPLETEDFORM

Return the completed form and any documentation to: If you need help completing this form, call:
(If no address is shown, return to your loan holder.) (If no telephone number is shown, call your loan holder.)
U.S.Department of Education Domestic 855- 265-4038

Fedloan Servicing Or Fax to: 717-7 20-1628 International: 717-720-1985
P.O.Box69184 TTY:dial 711. then enter 800-699- 2908
Harmburg, PA 17106-9184
Website. ~yf"cJL0Jr1.0ry
SECTION8: IMPORTANT INFORMATION ABOUT PSLF

You may obtain loan forgiveness under this program if you The Department will consider the lump sum payment
make 120 qualifying payments (see "Payment Eligibility'") on you have made as the equivalent of qualifying payments
eligible loans {see ··Loan Eligibility'") while working in equal to the lesser of (1) the number of payments resulting
qualifying employment {see ""Employment Eligibility"}. after dividing the amount of the lump sum payment by the
Payment Eligibility monthly payment amount you would have made under one
of the qualifying repayment plans listed below: or (2) 12
To receive PSLF,you must make 120 on-time, full,
payments.
scheduled, separate monthly payments on your Direct Loans
under a qualifying repayment plan after October 1, 2007. Peace Corps volunteers making an eligible lump sum
payment must do so within 6 months oft he Employment
On-time payments are those that are received by the
End Date, as reported in Section 3.
Department no later than 15 days after the scheduled
payment due date. Your payments must be made under a qualifying
repayment plan. Qualifying repayment plans include the
Full payments are payments on your Direct Loan in an
REPAYEplan, the PAYE plan, the IBR plan, the ICR plan, the
amount that equals or exceeds the amount you are required
10-Year Standard Repayment plan, or any other Direct Loan
to pay each month under your repayment schedule. If you
repayment plan, but only payments that are at least equal to
make a payment that is less than what you are required to
the monthly payment amount that would be required under
pay for that month, that month's payment will not count as
the 10-Year Standard Repayment plan.
one of the required 120 qualifying payments. If you make
multiple. partial payments in a month and the total of those Though repayment plans other than the REPAYE,PAYE,
partial payments equals or exceeds the required full IBR,and ICR plans are qualifying repayment plans for PSLF,
monthly payment amount, those payments will count as you must enter REPAYE,PAYE, IBR,or ICRto have a
one qualifying payment. remaining balance to forgive after becoming eligible for
PSLF.Otherwise, your loans will be fully repaid within 1O
Scheduled payments are those that are made while you
years. To apply for these plans, visit <,tuck-ntl 0.1n, gov.
are in repayment. They do not include payments made while
your loans are in an in-school or grace status, or in a IMPORTANT:The Standard Repayment Plan for Direct
deferment or forbearance period. Consolidation Loans made on or after July 1, 2006 have
repayment periods of different lengths. Monthly payments
You must make separate monthly payments. Lump sum
you make under the Standard Repayment Plan on such
payments or payments you make as advance payments for
Direct Consolidation Loans are only qualifying payments if
future months do not count as more than one qualifying
the loans have a 10-year repayment period (which would
payment. If you wish to make a payment in excess of your
only occur if your total education indebtedness is less than
scheduled monthly payment. follow the instructions on your
$7,500).
bill for providing payment instructions, and notate that your
payment 1snot intended to cover future installments. Loan Eligibility
Otherwise, your excess payment may affect your ability to
Only Direct Loan Program loans that are not in default
make future qua Iifying payments.
are eligible for PSLF.Loans you received under the Federal
If you were an AmeriCorps or Peace Corps volunteer, you Family Education Loan {FFEL) Program, the Federal Perkins
may receive credit for making qualifying payments if you Loan {Perkins Loan} Program, or any other student loan
make a lump sum payment by using all or part of a Segal program are not eligible for PSLF.
Education Award or Peace Corps transition payment.
Page 4 of 6

SECTION 8: IMPORTANT INFORMATION ABOUT PSLF (CONTINUED)

Loan Eligibility {Continued} Employment Eligibility [Continued)
If you have FFELProgram or Perkins Loan Program loans, You must be employed full-time by your employer.
you may consolidate them into a Direct Consolidation Loan
Generally, you must meet your employer's definition of
to take advantage of PSLF.However, payments made on
full-time. However, for PSLFpurposes, that definition must
your FFELProgram or Perkins Loan Program loans before
be at least an annual average of 30 hours per week. For
you consolidated them, even if they were made under a
purposes of the full-time requirement your qualifying
qualifying repayment plan, do not count as qualifying PSLF
employment at a 501 (c)(3) organization or a not-for-profit
payments. In addition, if you made qualifying payments on a
organization does not include time spent participating in
Direct Loan and then consolidate it into a Direct
religious instruction, worship services, or any form of
Consolidation Loan, you must start over making qualifying
proselyt1z1ng.
payments on the new Direct Consolidation Loan.
If you are a teacher, or other employee of a public service
If you consolidate your FFELProgram or Perkins Loan
organization, under contract for at least eight out of 12
Program loans into a Direct Consolidation Loan to take
months, you meet the full-time standard 1fyou work an
advantage of PSLFand do not have any Direct Loans, do not
average of at least 30 hours per week during the contractual
submit this form until you have consolidated your loans. The
period and receive credit by your employer for a full year's
on line application for Direct Consolidation Loans contains a
worth of employment.
section that allows you to indicate that you are
consolidating your loans for PSLF.The onl1ne application is If you are employed in more than one qualifying part-
available at ':ituden'.loans.gov. If you don"t know whether time job simultaneously, you may meet the full-time
you have Direct Loans, go to Stude11lAid.govilog111. employment requirement if you work a combined average
of at least 30 hours per week with your employers.
Vacation or leave time provided by the employer or leave
To qualify for PSLF,you must be an employee of a taken for a condition that is a qualifying reason for leave
qualifying organization. An employee Is someone who is under the Family and Medical Leave Act of 1993, 29, U.S.C.
hired and paid by the organization. You may physically 2612(a)(l) and (3) is equivalent to hours worked in qualifying
perform your work at a qualifying or non-qualifying employment.
organization. so long as your employer is a qualifying
Other Important Information
organization. If you are a contracted employee, the
organization that hired and pays you must qualify, not the The submission of this form before you apply for PSLFis
organization where you perform your work. The type or optional However, if you wait to submit this form until you
nature of employment with the organization does not apply for PSLF,you will be required to submit one form for
matter for PSLFpurposes. each employer that you want considered toward your
A qualifying organization is a government organization
or a tax-exempt organization under Section 501 {c)(3) of the If you submit this form and your employer qualifies, all of
Internal Revenue Code {IRC).Service In an Amer1Corps or your loans held by the Department will be transferred to
Peace Corps position is also qualifying employment. The FedLoan Servicing. Fedloan Servicing will then determine
type of services that these organizations provide does not how many qualifying payments you made during the period
matter for PSLFpurposes. of qualifying employment within the dates provided in
Section 3.
A private not-for-profit organization that is not a tax-
exempt organization under Section 501 (c)(3) of the IRC may You are not permitted to apply the same period of
be a qualifying organization 1fIt provides certain specified service to receive PSLFand the Teacher Loan Forgiveness,
public services. These services include emergency Service in Areas of National Need, and Civil Legal Assistance
management, military service, public safety, or law Attorney Student Loan Repayment programs.
enforcement services; public health services; public No borrower will be eligible for PSLFuntil October 2017
education or public library services; school library and other at the earliest. An application for PSLFwill be made available
school-based services; public interest law services: early at a later time.
childhood education; public service for individuals with
disabilities and the elderly. The organization must not be a
business organized for profit, a labor union, or a partisan
political organization.
Employment as a member of the U.S.Congress is not
qualifying employment.
Page~ of 6
PHeaa Employment Certification Review Manual


Privacy Act Notice. The Privacy Act of 1974 (5 U.5.C To assist program administrators with tracking
552a) requires that the following notice be provided to you: refunds and cancellations, disclosures may be made to
The authorities for collecting the requested guaranty agencies, to financial and educational instItutIons,
information from and about you are §421 et seq., §451 et or to federal or state agencies. To provide a standardized
seq., or §461 of the Higher Education Act of 1965, as method for educational institutions to efficiently submit
amended (20 U.5.C. 1071 et seq., 20 U.S.C.1087a et seq., or student enrollment statuses, disclosures may be made to
20 U.S.C.1087aa et seq.} and the authorities for collecting guaranty agencies or to financial and educational
and using your Social Security Number (SSNJare §§428B(f} institutions. To counsel you in repayment efforts, disclosures
and 484(a)(4J of the HEA {20 U.S.C.1078-2(1)and 1091(a)(4J) may be made to guaranty agencies, to financial and
and 31 U.5.C 7701 (bl. Participating in the William D. Ford educational institutions, or to federa I, state, or local
Federal Direct Loan {Direct Loan) Program, Federal Family agencies.
Education Loan {FFEL)Program, or Federal Perkins Loan In the event of litigation, we may send records to the
(Perkins Loan) Program and giving us your SSNare Department of Justice. a court, adjudicative body, counsel,
voluntary, but you must provide the requested information, party, or witness 1fthe disclosure is relevant and necessary
including your SSN,to participate. to the litigation. If this information, either alone or with
The principal purposes for collecting the other information, indicates a potential violation of law, we
information on this form, including your SSN,are to verify may send It to the appropriate authority for action. We may
your identity, to determine your eligibility to receive a loan send information to members of Congress if you ask them
or a benefit on a loan (such as a deferment, forbearance, to help you with federal student aid questions. In
discharge, or forgiveness) under the Direct Loan, FFEL,or circumstances involving employment complaints,
Federal Perkins Loan Programs, to permit the servicing of grievances, or disciplinary actions, we may disclose relevant
your loans, and, if it becomes necessary, to locate you and records to adjudicate or investigate the issues. If provided
to collect and report on your loans if your loans become for by a collective bargaining agreement, we may disclose
delinquent or default. We also use your SSNas an account records to a labor organization recognized under 5 U.S.C.
identifier and to permit you to access your account Chapter 71. Disclosures may be made to our contractors for
information electronically. the purpose of performing any programmatic function that
requires disclosure of records. Before making any such
The information in your file may be disclosed, on a
disclosure, we will require the contractor to maintain Privacy
case-by-case basis or under a computer matching program,
Act safeguards. Disclosures may also be made to qualified
to third parties as authorized under routine uses in the
researchers under Privacy Act safeguards.
appropriate systems of records notices. The routine uses of
Paperwork Reduction Notice. According to the
this information include, but are not limited to, its disclosure Paperwork Reduction Act of 1995, no persons are required
to federal, state, or local agencies, to private parties such as
to respond to a collection of information unless such
relatives, present and former employers, business and
collection displays a valid 0MB control number. The valid
personal associates, to consumer reporting agencies, to
0MB control number for this information collection is
financial and educational institutions, and to guaranty 1845-0110. Public reporting burden for this collection of
agencies in order to verify your identity, to determine your
information is estimated to average 30 minutes per
eligibility to receive a loan or a benefit on a loan, to permit
response, including time for reviewing instructions,
the servicing or collection of your loans, to enforce the searching existing data sources, gathering and maintaining
terms of the loans, to investigate possible fraud and to verify
the data needed, and completing and reviewing the
compliance with federal student financial aid program
collection of information. The obligation to respond to this
regulations, or to locate you if you become delinquent in collection is required to obtain a benefit in accordance with
your loan payments or if you default. To provide default rate
34 CFR685.219. If you have comments or concerns
calculations, disclosures may be made to guaranty agencies,
regarding the status of your individual submission of this
to financial and educational institutions, or to state
form. please contact your loan holder directly (see Section
agencies. To provide financial aid history information, 7).
disclosures may be made to educational instItutIons.
Page6of6
Employment Certification Review Manual

Resources/Authority
34 CFR 685.219


To: Diane Fre11ndel
Cc: Kimberly A Myers
Subject: PSLF Employer Escalation Meeting Mlnutes_01302017
Date: 08/01/2017 01 :43 PM
Diane:
This chain references several attachments. Are you or Kim able to get them for me?
I believe they may be responsive.
• January 30, 2017 meeting minutes

• PSLFCR (I believe Kim already gave this to me)
• email from 2012 from Ian referenced below
• 2012 "standardreview process"
Also, can you print the email for me (since we are producing it, I cannot produce it as
a forward)?

AES/PHEAALegal & Compliance Services
1200 N. 7th Street
telephone# (717) 720-1568
fax# (717) 720-3911
Diane Freundel---07/25/2017 11 :29:41 AM---l'm not sure if this is helpful, but I'd
ratherprovide
to youandyoucandecide.DianeEreundel
From Diane Freundel/PHEAA
To· James J Jarecki/AES@PHEAA,Andrew Petsu/PHEAA@PHEAA
Oate· 07/25/201711:29AM
S"mjocl: PSLFRTK: Fw: [external]RE: PSLFEmployer Escalation Meeting
Minutes_01302017
I'm not sure if this is helpful, but I'd rather provide to you and you can decide.
Diane Freundel
ComplianceServices
(717) 720-3267
dfreunde@pheaa.org
----- Forwarded by Diane Freundel/PHEAA on 07/25/2017 11 :28 AM -----
From. "Foss, Ian" <lan.Foss@ed.gov>

To Fedloan PSLF<FedLoanPSLF@pheaa.org>, "Chialastri, Taneka"
< T aneka.Chialastri@ed.gov>
Cc "Odom, Christian" <Christian.Odom@ed.gov>, "Battle, Cynthia"
<Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde@pheaa.org>, "'Lauren
M. Swett"' <lswett@pheaa.org>, l(b)(5) I l(b)(5) I
D:1te 02/03/2017 01 :48 PM
S.JOjecl [external]RE: PSLFEmployer Escalation Meeting Minutes_01302017
Thanks a lot, Kim!
Question: the document you attached seems to cover only one component of the
review process associated with non-50 I (c)(3) not-for-profit organizations;
namely, how you determine whether the organization is a not-for-profit. It
doesn't seem to discuss the qualifying service component of the review. Can
you clarify? A literal reading of the document would lead someone to believe
that you would approve any non-50l(c)(3) not-for-profit organization. Since we
get emails from you about whether organizations provide qualifying public
services, we know you are looking for it. However, is that documented
anywhere?
Basically, we have three documents:
The initial PSLF CR, which incorporated the 20 l l ECF processing guide
by reference. This guide required you to escalate all non-50l(c)(3) non-profits
to us unless.
The email from me in 2012, which, though ambiguous in hindsight, told

you that, at a minimum, you didn't need to escalate organizations that were not
governmental or 50 I (c)(3)s if you could determine that they were for-profit
organizations.
The 2012 "standardized review process", which does incorporate the

guidance that I sent in 2012 related to for-profits, but doesn't address under
what circumstances things would be escalated to us.
Also, I'm still not I 00% sure under what circumstances you escalate to FSA
Did you interpret my 2012 email to, for example, allow you to only escalate
organizations if you were not sure that they qualified, i.e., that there was no
need to escalate organizations if you were confident that they qualified?
From: Kimberly A Myers rmailto:kmyers@pheaa.org l On Behalf Of FedLoan

PSLF

Cc: Odom, Christian; Battle, C 1nthia; Diane Freundel; 'FedLoan PSLF; Foss,
Ian; 'Lauren M. Swett'; (b)(5J
~-~~~
Subject: Re: PSLF Employer Escalation Meeting Minutes_0l302017
Hi Taneka! Realized l forgot the attachment.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From: FedLoan PSLF/PHEAA

To: "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>
Cc: "Odom, Christian" <Christian.Odom@ed.gov>, "Battle, Cynthia"
<Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde@pheaa.org>, "'FedLoan
PSLF'" <FedLoanPSLF@pheaa.org>, "Foss, lan" <lan.Foss@ed.gov>, "'Lauren
M. Swett'" <lswett@pheaa.org>, l(b)(5J IL(b_l(_51
_______ ~
Date: 02/03/2017 12:34 PM
Subject: Re: lexternalJlexternalJPSLF Employer Escalation Meeting
Minutes 01302017
Sent by: Kimberly A Myers
Hi Taneka!
We recall both the discussion with Ian and receiving the ECF Processing
Protocol in December 2011, that was shared with the Business Unit to be used
when processing ECFs.
Our interpretation of lan's email was that we should internally deny any ECF
where we could conclusively determine for-profit status, regardless of which
box was checked on the ECF. ln addition, through subsequent discussions with
Ian, it was also our understanding that if we were unable to determine
eligibility, the onus of proving an organization's eligibility is on the boJTower
and employer to provide the necessary information. Due to questions
surrounding the escalation process, we internally created a 'Standardized
Review Process·. We vetted the document through FSA. We are currently
following the process outlined in this document, with some modifications.
Since the date this document was created, we found additional resources we use
to further determine qualifying status. We attached the most recent version we
have on file (from April 2012).
Also, I understand Diane had a brief discussion with Ian this morning about the
ABA and AILA. As we recall, we first escalated the AILA in May 2014 when
we received an ECF for the organization. In June 2014 Ian replied that he
agreed with our assessment that the organization did not qualify. Subsequently
in December 2014, Ian sent us the letter from Jeff Baker to Ms.~ advising
her that the Department was retracting its previous assessment of the AILA's
eligibility. That was the first indication we had that the Department had
determined the AILA was eligible.
I think Diane said Ian also had some questions about the ABA timeline. I had
sent him an email on 4/8/2016 with a summary of what transpired with the
ABA. I can resend if needed.
--- I hope to be able to provide you, by COB today, the information on the
50l(c)(4) organizations that you requested.
--- We currently have 2 staff who devote approximately 25 hours total a week
on ECF escalations. On average, we receive about 340 escalations per month.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From: "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>

To: "'Kimberly A Myers'" <kmyers@pheaa.org>, Diane Freundel
<dfreunde@pheaa.org>, "'Lauren M. Swett'" <lswett@pheaa.org>, "'FedLoan
PSLF''' <FedLoanPSLF@pheaa.org>
Cc: ''Battle, Cynthia" <Cynthia.Battle@ed.gov>, "Foss, Ian"
<Ian.Foss@ed.gov>, "Odom, Christian" <Christian.Odom@ed.gov>,
l(b)(5J I(b)(5J "Chialastri, Taneka"
<Taneka.Chialastri@ed.gov>
Date: 02/01/20 I7 04:28 PM
Subject: lexternalH externalJPSLF Employer Escalation Meeting
Minutes_0\302017
Hi Kim,
Thanks again to you and the rest of the team at FedLoan for meeting with FSA
to discuss the Employer Escalation process. Attached are meeting minutes, a
2012 email from Ian to FedLoan regarding the employer escalation process, and
a version of the ECF Processing Protocol from Dec. 2011 that we were able to
locate in our archives. For the email - could you tell us if FedLoan interpreted
the email guidance to mean that Compliance didn't need to escalate PSLF
determinations that were for-profit (only), or if Compliance didn't need to
escalate any organizations to FSA if they were confident in their decision? For
the protocol - could FedLoan confirm if this document was provided to the
business unit to use as a rubric for reviewing employer escalations?
After the meeting, we also realized that there were a few outstanding questions
that we still need clarification on. If you could provide responses as soon as
possible to the two questions (below) it would be much appreciated.
Would FedLoan be able to provide the total number of 501(c)(4)

organizations that have come through Compliance for review and the
breakdown of approvals, denials, and accounts escalated to FSA?
Would FedLoan be able to tell us how many full-time staff in Compliance
are working on escalations and what the average monthly volume is?
Please let me know if there are any questions regarding this email or edits to the
meeting minutes.
Thanks,
Taneka
----------------------------------
Taneka Chialastril Management and Program Analyst, Business Operations I
Federal Student Aid
830 First Street NE, Washington, DC 20202
Office: 202-377-4390 I Cell: 202-256-78421 taneka.chialastri@ed.gov
5_1
----- Message from Ll(b_l(__ ~1 5
L(b_l(
_1_______ J on Wed, I Feb 2017
19:34:57 +0000 -----
:To "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>
:Subject Fw: Columbia Physical Therapy PS
From: l(bl( 5l
~~-~-,---'
Sent: Tuesday, February 28, 2012 7:45 AM
To: FedLoan PSLF
Cc: l(bl(5l I Foss, lan; Ninemire, Sandra; Sipple-Asher, Bessie; Johnson,
Debbe
Subject: RE: Columbia Physical Therapy PS
l agree that this is a for-profit entity and therefore does not qualify. You
may stop escalating cases where the employer is clearly for-profit. lf it's
a close case, or you're not sure that it's a clear case, then go ahead and
continue escalating it.
> -----Original Message-----

> From: Diane Freundel
lmailto:dfreunde@aessuccess.orgj On Behalf Of
> FedLoan PSLF
> Sent: Monday,
February 27, 2012 8:07 PM
> To: !(b1(51 I
> Subject: Columbia Physical
Therapy PS
>
>
> Hi, Please see the attached ECF and information from the
WA Corporations
> Division. This entity is for profit. Please let us know
if you want to
> continue to see entities that checked box c that are for
profit. Password
> to follow. Thanks!
>
> (See attached file: Columbia
Physical Therapy_Hodgson.zip)
>
> Diane Freundel
> Compliance Services
>
(717) 720-3267
> fax-(717) 720-3911
> dfreunde@pheaa.org
>
>
--------------------
> This message contains privileged and confidential

> the above addressees only. If you receive this
message in error please
> delete or destroy this message and/or
attachments.
>
> The sender of this message will fully cooperate in the
civil and criminal
> prosecution of any individual engaging in the
> message.
>
>
Code:PHEAA
From: John A Reedy

To; ShellyL Dreese
Subject: Fw: PSLFRetraction Letters
Date: 11/16/2016 11:03 AM
Ploaso mako s11rothat larrod is aware of tho below wbilo comolotina PSDl\11 tasksl(bl( 5l
Thank you,
John Reedy
Escalated Research T earn Supervisor
Loans Operation I Pennsylvania Higher Education Assistance Agency
Hours: Mon - Fri 7:30 AM - 4:30 PM
717.720.1948
Forwarded by John A Reedy/ AES on 11/16/2016 11 :02 AM -----
lrom: Brenda Gossard/PHEAA

To John A Reedy/AES@PHEAA, Shelly L Dreese/AES@PHEAA
Cc cguido@aessuccess.org, Brittany L Wagner/AES@PHEAA, Kayce R Gregory/AES@PHEAA,
Jody Teter/PHEAA@pheaa
D:1te 11/16/201610:15AM
S,Jbject PSLF Retraction Letters
Guidance has now been received that FSA wants to review every retraction letter we
send when overturning an approved ECF. Please make sure the steps below are
added into any procedures you may have. Let us know if you have any questions.
Thanks!
Brenda Gossard
Call Center Manager
FedLoan Servicing
Office: (717) 720-2484
----- Forwarded by Brenda Gossard/PHEAA on 11/16/2016 10.11 AM -
Frolll Fedloan PSLF/PHEAA

To FLS PSLF Supervisor Review/Fedloan Servicing@PHEAA
Cc· Brenda Gossard/PHEAA@pheaa, Jody Teter/PHEAA@pheaa, Kayce R
Gregory/AES@PHEAA, Brittany L Wagner/AES@PHEAA, Melissa L Shoemaker/AES@PHEAA,
Matthew J Eshelman/AES@PHEAA, Diane Freundel/PHEAA@pheaa
[)ate· 11/16/201610:08 AM
S"ibJcct: Fw: [external]RE: RE: Re: Re: Re: Re: PSLF - American Bar Association
Good morning! Recently FSA has been asking for more detail in regards to
denials/retractions, etc. Based on the most recent query they requested, they now
want to review EVERYretraction that is performed (see below email from FSA).
Effective immediately, you should not retract any approvals without first escalating to
Compliance. This would also include instances where a processor approved an
employer in error without reviewingprior guidance (e.g. Compliancedenied an

employer in the database and a future processor approved the employer in error
without reviewing the guidance). As a result, you should not be taking action by way
of clean-ups to reverse any previous approvals prior to escalating to us.
We clarified with FSA that the copy of the retraction letter would not be available
until after they provide the decision on the retraction and your team updates the
account.
Please let us know if you have any questions. Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Forwarded by Kimberly A Myers/PHEAA on 11/16/2016 09:16 AM
From l(b)(5) I (b)(5)

To· FedLoan PSLF<"Fe~d"L~o~a,~P~S"LF"'@'p~h~e~a~a.~o"cg>
Cc: "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde@oheaa.org>,
"Utz Joo" <Joo Utz@ed!ov>, "Foss, Ian" <lan.Foss@ed.gov>, ,l(b~l(~51~-~J
l(b)(5) _ "Odom, Christian" <Christian.Odom@ed.gov>
Date: 11/15/201604:38PM
S,Jbject [external]RE: RE: Re: Re: Re: Re: PSLF- American Bar Association
Th;rnk you ;ig;iin for providing df'tails to us rf'gard1ng the retr;ict1on process Moving forward, FSA
would like to review and approve all retraction cases related to employment prior to servicer
processing.
WP.envision th,1t the procP.ss will he similar to thP. P.mployP.rP.scalat1onscurrently forv,JardP.dto FSA
for review. [ffcct1vc immediately, we would like to receive the follov1,1ing1nformat1on for each case
via the PSLFin box (b)(5)
~-------~
Rea"or1 for lhe relraclion;
Number of borrov,/P.rs impacted;
Date of the oldest approval,
A copy of the retraction letter;
ECF{s}; and
any resP.arch th,1t Fed Loan has alrP.ady conductP.d on the employer
Since many of these retractions arc time scns1t1ve, FS/\ will make every effort to provide a decision
back to Fed Loan within 3-5 business days
Ple,1sP.IP.t us know 1fyou have concP.rns with this request or 1fyou neP.d ,1dditional information
l(ind regards,
Taneka
From: l(bl(51 I
Sent: Thursday, October 20, 2016 3:05 PM
To: Fedloan PSLF; l(bl(51 I
Subject: RE: RE: Re: Re: Re: Re: PSLF - American Bar Association
Thank you, l<im. This is really helpful information We will discuss on this side and will get back to
you.
Kind Reg,1rds,
Taneka
From: Kimberly A Myers [ ~] On Behalf 01 Fedloan PSLF

Sent: Tuesday, October 18, 2016 3:53 PM
To: l(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; 'Fedloan PSLF'; Utz, Jon; Tiongquico, Rene
Hi Tankea! Again, I apologize for the delay. I wanted to ensure I provided you with
employers, with a breakdown as follows: 4 in 2012, 37 in 2013, 123 in 2014, 64 in
Based on internal reviews (those outside of the employers we escalated to FSA), the
clarifyinginformationdue to conflictinginformationreceivedvia a later ECF, the
borrowerwas determinedto be a volunteer, etc). Just to note, some of the retractions
were due to the borrower providing inaccurate information on the initial ECF which
wasn't identified until he/she submitted a subsequent ECF with conflicting
information.
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From l{b)(5) I(b)(6)

Tn "'FedLoan PSLF"' <FedLoanPSLF@pheaa.org>, 1-1b-J(5-l_~l c-b_l(_ 61~~---=~~-,,
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dlreunde@pheaa.org>, "Utz, Jon" <Jon.Utz@ed.gov>,
"Tiongquico, Rene" <Rene Tipngguico@ed.gov>
Dale 10/1712016 03:52 PM
Sub1cct [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
I just wanted to follow-up to find out if you were able to find out the average number of
retractions that are issued by PHEAA.
Thanks,
Taneka

51
To: 'Fedloan PSLF'; !(b1( I
Hi Kim,
Do you have an idea of the average number of retractions that are issued by PHEAAon a
yearly basis? Additionally, would you know about how many of those retractions are for
employers who were non-profit that we determined did not provide a qualifying service and
those who PHEAAjust determined were for-profit?
Tentatively, I would say that we would like to be aware of all retractions, especially in the
instance where the retraction is going out years after the borrower's employment is
approved, and be able to review the letters before going out to borrowers. We'll wait to hear
about the volume that you anticipate we would need to review before making any decisions.
Thanks,
Taneka
Hi Taneka! Historically, if an employer retraction is because of changing guidance,

etc, we will escalate those to you before taking action. However, if we discover
internally that an employer was approved in error by a processor (e.g. employer was
accidentally approved but it was always for-profit), we will take care of those internally
and not escalate. Based on your wording below, would you now expect these
situations to be routed to you first before we take action, even though we know the
approval an obviouserror?
We can definitely forward the retraction letter to you before they are sent to the
borrower. Just for our knowledge,would you expect to have a quick turnaroundin
reviewing these letters so that we can get them out to the borrower as soon as
possible?
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From l{b)(5) ll(b)(5)

Cc "'Battle. Cynthia" <Cynthia.Bal1le@ed.gov>. Diane Freundel <dfreunde@pheaa.org>, "'Utz, Jon'" <Jon.Utz@ed.gov>,
"Tiongquico, Rene" <Rene T19ngguico@ed.gov>. "Chialastri, Taneka" <Taneka.Ch1a1astri@ed.gov>
D,1te 10/12/201610:11 AM
Suhw:;t [external]Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
Kind Regards,
Taneka

Sent: Friday, October 7, 2016 1:52 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; FedLoan PSLF;Utz, Jon; Tiongquico, Rene; Chialastri,
Taneka
Subject: Re: Re: Re· Re· PSLF- American Bar Association
Hi Taneka! You are correct in you assumption for the retraction tab. The processed
date is the date it was approved. Essentially it all occurs in one step (the ECF is
processed as an approval).
With the retraction letters, we had previously advised that the Business Unit that they
need to include more detail. Previously it was very generic (it just basically stated
that the employer was retracted, but didn't give much explanation as to why). It has
gotten better, but we can certainly work more with the Business Unit to "beef" up the
denial letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
f-10111 l{b)(5) I b)(6)

To Fedloan PSLF <FedLoanPSLF@pheaa.org>
Cc "Battle, Cynthia" <Cynthia.Bal1le@ed.gov>. Diane Freundel <dfreunde@pheaa.org>, "Tiongquico, Rene"
<Rene.Tionqquico@ed gov>, "Chialastri, Taneka"< Taneka Chialastri@ed gov>, "Utz, Jon" <,Jon.Utz@edgov>,
l{b)(5) I b)(6)
Dale 10/0712016 01 :47 PM
Sub1ect [external]Re: Re: Re: PSLF - American Bar Association
Hi Kim,
In regards to the retraction letter - I know we previously discussed PHEAA providing more
detail in the retraction letter and I recall the Business Unit making a few changes; however, I
think we may need to revisit the way the retraction letters are drafted to ensure that we are
being as transparent as possible to borrowers who are being informed that a previously
qualified employer is no longer eligible. I'm going through emails and noticed the retraction
letter is similar for borrowers employed with Students First so wanted to make sure that we
make every effort to make sure borrowers are informed.
Thank you,
Taneka
From: Kimberly A Myers <kmyers@pheaa.org> on behalf of Fed Loan PSLF

Sent: Friday, October 7, 201612:26:29 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; Fed Loan PSLF;Tiongquico, Rene; Chialastri, Taneka
Hi Taneka! I was able to pull together the information you requested (no pressure for
a mid-Friday) : )
I attached a spreadsheet which provides the borrowers whose ECFs were approved
then retracted, as well as the borrowers whose ECFs were denied outright. The
spreadsheet has two tabs with each cohort of borrower.
For the borrower whose approval was retracted after 45 months, I included the letters
we have on record. There is one system generated denial letter, one system
generated approval letter, and the manual retraction letter. Just a head's up on the
system generated denial letter. His ECF was originally not complete, so the denial is
for missing information. He returned another, complete, ECF which is the one that
was approved.
If there is anything else you need, please do not hesitate to ask. Password to follow.
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
From l{b)(5)
-~~
I<publicservice@ed.gov>
Cc Diane Freundel <dfreunde@pheaa.org>, "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>, "Tiongquico. Rene"

<Rene.Tionqquico@ed gov>, "Battle. Cynthia" <Cynthia Battle@ed.gov>, FedLoan PSLF <FedLoanPSLF@pheaa orq>,
b 5 (b)(6)
Dale 10/071201610:28 AM
Sub1ect [external]Re: Re: PSLF American Bar Association
Hi Kim,
Thanks,
Taneka

Sent: Wednesday, April 13, 2016 8·34·28 AM
To: Foss, Ian
Hi Ian! Attached is a redacted copy of the ECF and corresponding retraction letter to
the borrower. Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From "Foss, Ian" <Ian Foss@ed.gov>
Io Kimberly A Myers <kmyers@pheaa.org>
Cc Diane Freundel <dlreunde@pheaa.org>, "Chialastri, Taneka" <Taneka.Ch1alastr1@ed.gov>
Dale 04/13/2016 08:42 AM
SubIcct [external]Re: PSLF - American Bar Association
Hi Ian!
Based on the query the BusinessUnit performed,there were 9 borrowerswho were

denied outright and a total of 19 that received retraction letters. Of the 19 who
received retractionsletter, 14 were picked up in this most recent query the Business
Unit ran.
Business Unit only retracted about 10 months of employment (from 8/2011 to
5/2012).
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
Tr: "'Kimberly A Myers"' <kmyers@pheaa ora>
Cc Diane Freundel <dfreunde@pheaa.org>, "Chialastri, Taneka" <Taneka.Chia1as1ri@ed.gov>
D,1te 04/08/2016 02:56 PM

Suhw:;t [external]RE: RE: PSLF - American Bar Association
Can you give me a sense of how many borrowers received a retraction regarding the ABA and
how many received outright denials? Also, for those retracted, how long after the approval did
the retraction go out {for the borrower for whom it was the longest)?

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we had
forwarded any other "Bar" or "Bar Associations" for review. Although we didn't
escalate the employer, I know you also initially made a determination on the
American Immigration Lawyers Association (which Jeff Baker also drafted a letter to
I know in the beginning we were struggling with associations in general and

specifically organizations that would qualify under the "public interest legal services"
category. At one point, I know we had talked through it over the phone, which gave
us a clearer understanding of this category. Once we grasped what organization
would/would not qualify under this category, we internally made the decisions and
only escalated to you the ones we were on the fence about.
In regards to the American Bar Association, we made the decision internally that they
do not qualify and provided this guidance to the Business Unit. As we received ECFs
from borrowers employed by the American Bar Association, we were denying.
I know in some instancesthere were borrowerswho were certifiedas workingin a

qualifyingarm of the American Bar Association(e.g. American Bar AssociationFund
for Justice and Education under the EIN 36-6110299). If we had a reason to question
it, we would request the borrower's W-2 to confirm who actually paid the borrower. In
most instances, the borrower turned out to be employed by the American Bar
Association directly under the EIN 36-0723150. In light of your decision on ACLU, we
now have reason to questionthis further.
We were recently escalated an account for the American Bar Association where the
previous approval had not been retracted. As a result, the Business Unit ran a query
to identify and clean up those borrowers who may have been approved under the
American Bar Association in the past who should not have been. This is most likely
where the retractionof the previousapprovalcame from.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630

To "Foss, Ian" <Ian Foss@ed.gov>. Diane Freundel <dfreunde@pheaa org>, "'Kimberly A Myers"'
<kmyers@pheaa.org>
Date 04/08/201612:02 PM
Sul1iec1 [external]RE: PSLF - American Bar Association
Hi Ian,
I don't show anything on record for the American Bar Association I only have documentation
of decisions made regarding the King County Bar Association, Bar Association of San Francisco,
State Bar of Wisconsin, and the District of Columbia Bar.
Thanks,
Taneka
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLFand the American Bar
Association? We just got a letter saying we approved them and then retracted it several years
later. I'm not finding record that I worked on it personally, but that doesn't mean its so.
Thanks,
Ian
addressees only. If you receive this message in eITor please delete or destroy this message
and/or attachments.
Code:PHEAA
From: Brenda Gossard

To; ,JohnA Reedy: Shelly L Dreese
Cc: c911ido@aess11ccessom: Brittany L Wagner; Kayce R Gregory: ,JodyTeter
Subject: PSLF Retraction Letters
Date: 11/16/201610:15 AM
Guidance has now been received that FSA wants to review every retraction letter we
send when overturning an approved ECF. Please make sure the steps below are
added into any procedures you may have. Let us know if you have any questions.
Thanks!
Brenda Gossard
Call Center Manager
Fedloan Servicing
Office: (717) 720-2484
Forwarded by Brenda Gossard/PHEAA on 11/16/2016 10;11 AM -----
From· Fedloan PSLF/PHEAA

To FLS PSLF Supervisor Review/Fedloan Servicing@PHEAA
Cc Brenda Gossard/PHEAA@pheaa. Jody Teter/PHEAA@pheaa. Kayce R
Gregory/AES@PHEAA. Brittany L Wagner/AES@PHEAA, Melissa L Shoemaker/AES@PHEAA,
Matthew J Eshelman/AES@PHEAA,Diane Freundel/PHEAA@pheaa
Date 11/16/201610:08 AM
SJbject· Fw: [external]RE; RE; Re; Re; Re; Re; PSLF- American Bar Association
Sent by; Kimberly A Myers
employer in error without reviewing prior guidance (e.g. Compliance denied an
account.
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Forwarded by Kimberly A Myers/PHEAA on 11/16/2016 09·16 AM
Frolll l(b)(5) I
,;.(b~)(5,,.1
_____ ~
To Fedloan PSLF<FedLoanPSLF@pheaa.org>
Cc: "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dfreunde pheaa.org>,
"Utz, Jon" <Jon.Utz@ed.gov>, "Foss, Ian" <lan.Foss@ed.gov>, ~(b~)(5~)-~
(b)(5) "Odom,Christian"<Christian.Odom@ed.gov>
Date 11/15/2016 04:38 PM
SJbject· [external]RE:RE: Re: Re: Re: Re: PSLF- AmericanBar Association
111l(im,
Thank you again for providing details to us regarding the retraction process Moving forward, FSA
would like Lo review and approve all relraclior1 cases relaled lo employment prior lo servicer
processing.
We envision that the process will be similar to the employer escalations currently forwarded to FSA
for review. Elleclive 1mmed1alely, we would like lo receive Lhe following informalion for each case
v1;i the PSLFin box (b)(5)
~~-------"
Number of borrowers impacted;
Dale ol lhe oldesl approval,
A rnpy of the retr;iction letter;
[CF(s), and
any research that FedLoan has already conducted on the employer.
Since mar1y of lhe:,e relraclions are lime-serhilive, FSA will make every efforl lo provide a decision
hack to Fedlo;in 1.1.J1th1n
3-.S business d;iys
Please let us know if you have concerns with this request or if you need additional information.
Kind regards,
Taneka
From: l(bl(51 I
To: FedLoan PSLF; l(bl(51 I
Thar1k you, Kim. This 1sreally helplul 1nlormal1on VVe will discuss on lh1s :,ide and will gel back Lo
you
l(ind Regards,
Taneka
From: Kimberly A Myers [ ~] On Behalf Of Fedloan PSLF

To: l(bl(51 I
Cc: Battle. Cynthia; Diane Freundel; "Fedloan PSLF";Utz. Jon; Tiongquico, Rene
Subject: Re: RE: Re: Re: Re: Re: PSLF- American Bar Association
Hi Tankea! Again. I apologize for the delay. I wanted to ensure I provided you with
employers. with a breakdown as follows: 4 in 2012, 37 in 2013, 123 in 2014. 64 in
Based on internal reviews (those outside of the employers we escalated to FSA). the
clarifying information due to conflicting information received via a later ECF, the
borrowerwas determinedto be a volunteer,etc). Just to note, some of the retractions
were due to the borrowerprovidinginaccurateinformationon the initialECF which
wasn"t identified until he/she submitted a subsequent ECF with conflicting
information.
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
f-10111 l(b)(5) ll(b)(5)

Tc '"Fedloan PSLF"' <FedLoanPSLF@pheaa.org>, 1-(b~)(5~1-~11-(b~)(5~)----~
Cr: "Battle, Cynthia" <Cynthia.Battle@ed.gov>. Diane Freundel <dfreunde@pheaa orq>, "Utz, Jon" <Jon Utz@ed.gov>,
"Tiongquico, Rene" <Rene.T1ongciuico@ed.gov>
Date 10/17/2016 03:52 PM
Sul1iecI [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
I just wanted to follow-up to find out if you were able to find out the average number of
retractions that are issued by PHEAA.
Thanks,
Taneka

Sent: Wednesday, October 12, 2016 11:22 AM
Hi Kim,
Do you have an idea of the average number of retractions that are issued by PHEAA on a
yearly basis? Additionally, would you know about how many of those retractions are for
employers who were non-profit that we determined did not provide a qualifying service and
those who PHEAAjust determined were for-profit?
Tentatively, I would say that we would like to be aware of all retractions, especially in the
instance where the retraction is going out years after the borrower's employment is
approved, and be able to review the letters before going out to borrowers. We'll wait to hear
about the volume that you anticipate we would need to review before making any decisions.
Thanks,
Taneka
Hi Taneka! Historically,if an employer retractionis because of changingguidance,

etc, we will escalate those to you before taking action. However, if we discover
internally that an employer was approved in error by a processor (e.g. employer was
accidentally approved but it was always for-profit), we will take care of those internally
and not escalate. Based on your wording below, would you now expect these
situations to be routed to you first before we take action, even though we know the
approvalan obviouserror?
We can definitely forward the retraction letter to you before they are sent to the
borrower. Just for our knowledge, would you expect to have a quick turnaround in
reviewingthese lettersso that we can get them out to the borroweras soon as
possible?
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
Frrnn publicservice~b=5~----~
Io FedLoan PSLF <FedLoanP$LF@pheaa.org>
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dlreunde@pheaa.org>, "Utz, Jon" <Jon.Utz@ed.gov>,
"Tiongquico, Rene" <Rene.Tiongquico@ed.gov>. "Chialastri, Taneka" <Taneka.Chialastri@ed.gov>
Date 10112/201610:11 AM
Sub1ect [external]Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
Kind Regards,
Taneka

To: !(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; Fed Loan PSLF;Utz, Jon; Tiongquico, Rene; Chialastri,
Taneka
Hi Taneka! You are correct in you assumption for the retraction tab. The processed
date is the date it was approved. Essentially it all occurs in one step (the ECF is
processed as an approval).
With the retraction letters, we had previously advised that the Business Unit that they
need to include more detail. Previously it was very generic (it just basically stated
that the employer was retracted, but didn't give much explanation as to why). It has
gotten better, but we can certainly work more with the Business Unit to "beef" up the
denial letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
From l(b)(5) ll(b)(5)
Tr: FedLoan PSLF <FedLoanPSLF@pheaa QrQ>

Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dlreunde@pheaa.org>, "Tiongquico, Rene"
<Rene.Tiongguico@ed.gov>. "'Chialastri, Taneka'" <Taneka.Chialastri@ed.gov>, "Utz, Jon"' <Jon.Utz@ed.gov>,

l{b)(5) I (b)(6)
Date 1010712016 01 :47 PM
Sub1ect [external]Re: Re: Re: PSLF - American Bar Association
Hi Kim,
In regards to the retraction letter - I know we previously discussed PHEAA providing more
detail in the retraction letter and I recall the Business Unit making a few changes; however, I
think we may need to revisit the way the retraction letters are drafted to ensure that we are
being as transparent as possible to borrowers who are being informed that a previously
qualified employer is no longer eligible. I'm going through emails and noticed the retraction
letter is similar for borrowers employed with Students First so wanted to make sure that we
make every effort to make sure borrowers are informed.
Thank you,
Taneka

To: i(b1(51 I
Cc: Battle, Cynthia; Diane Freundel; FedLoan PSLF;Tiongquico, Rene; Chialastri, Taneka
Hi Taneka! I was able to pull together the information you requested (no pressure for
a mid-Friday) : )
I attached a spreadsheet which provides the borrowers whose ECFs were approved
then retracted, as well as the borrowers whose ECFs were denied outright. The
spreadsheet has two tabs with each cohort of borrower.
For the borrower whose approval was retracted after 45 months, I included the letters
we have on record. There is one system generated denial letter, one system
generated approval letter, and the manual retraction letter. Just a head's up on the
system generated denial letter. His ECF was originally not complete, so the denial is
for missing information. He returned another, complete, ECF which is the one that
was approved.
If there is anything else you need, please do not hesitate to ask. Password to follow.
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
From l{b)(5)
Cc Diane Freundel <dlreunde@pheaa.org>, "Chialastri, Taneka" <Taneka.Ch1alastr1@ed.gov>, "Tiongquico, Rene"
<Rene.Tian UICO ed. OV>, "Battle, C nthia" <Cynthia.Battle@ed.gov>, Fedloan PSLF <FedLoanPSLF@pheaa.org>,
l{b)(5) I b)(6)
Suhw:;t [external]Re: Re: PSLF American Bar Association
Hi Kim,
Thanks,
Taneka

To: Foss, Ian
Hi Ian! Attached is a redacted copy of the ECF and corresponding retraction letter to
the borrower. Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
Cc Diane Freundel <dfreunde@pheaa.org>, "Chialastri, Taneka'" <Taneka.Chia1as1ri@ed.gov>
D,1te 04/13/2016 08:42 AM

Hi Ian!
Based on the query the Business Unit performed, there were 9 borrowers who were
denied outright and a total of 19 that received retraction letters. Of the 19 who
received retractionsletter, 14 were picked up in this most recent query the Business
Unit ran.
Business Unit only retracted about 10 months of employment (from 8/2011 to
5/2012).
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Frrnn "Foss, Ian" <Ian Foss@ed.gov>
Io ""'Kimberly A Myers"'" <kmyers@pheaa.org>
Cc Diane Freundel <dfreunde@pheaa org>, "Chialastri, Taneka" <Taneka Ch1alastri@ed gov>
Dale 04/08/2016 02:56 PM

Sub1ect [external]RE: RE: PSLF - American Bar Association
Can you give me a sense of how many borrowers received a retraction regarding the ABA and
how many received outright denials? Also, for those retracted, how long after the approval did
the retraction go out {for the borrower for whom it was the longest)?
From: Kimberly A Myers [mailJo:kmyers@pheaa.org]

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we had
forwarded any other "Bar" or "Bar Associations" for review. Although we didn't
escalate the employer, I know you also initially made a determination on the
American Immigration Lawyers Association (which Jeff Baker also drafted a letter to
I know in the beginningwe were strugglingwith associationsin general and

specifically organizations that would qualify under the "public interest legal services"
category. At one point, I know we had talked through it over the phone, which gave
us a clearer understandingof this category. Once we grasped what organization
would/would not qualify under this category, we internally made the decisions and
only escalated to you the ones we were on the fence about.
In regards to the American Bar Association, we made the decision internally that they
do not qualify and provided this guidance to the Business Unit. As we received ECFs
from borrowersemployed by the American Bar Association,we were denying.
I know in some instancesthere were borrowerswho were certifiedas workingin a

qualifyingarm of the American Bar Association(e.g. American Bar AssociationFund
for Justice and Education under the EIN 36-6110299). If we had a reason to question
it, we would request the borrower's W-2 to confirm who actually paid the borrower. In
most instances, the borrower turned out to be employed by the American Bar
Association directly under the EIN 36-0723150. In light of your decision on ACLU, we
now have reason to question this further.
We were recentlyescalated an accountfor the American Bar Associationwhere the

previous approval had not been retracted. As a result, the Business Unit ran a query
to identify and clean up those borrowers who may have been approved under the
American Bar Association in the past who should not have been. This is most likely
where the retraction of the previous approval came from.
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630

Tr: "Foss, Ian" <Ian Foss@ed.gov>. Diane Freundel <dfreunde@pheaa orq>, "'Kimberly A Myers"'
<kmyers@pheaa.org>
D,1te 04/08/201612:02 PM
Sullj8CI [external]RE: PSLF - American Bar Association
Hi Ian,
I don't show anything on record for the American Bar Association I only have documentation
of decisions made regarding the King County Bar Association, Bar Association of San Francisco,
State Bar of Wisconsin, and the District of Columbia Bar.
Thanks,
Taneka
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLFand the American Bar
Association? We just got a letter saying we approved them and then retracted it several years
later. I'm not finding record that I worked on it personally, but that doesn't mean its so.
Thanks,
Ian
addressees only. If you receive this message in error please delete or destroy this message
and/or attachments.
Code:PHEAA
From: Fedloan PSLF

Sent By: Diane Freundel
To: ian.foss@ed.gov
Subject: Public: Fw: American Immigration Lawyers Assoc1at1on
Date: 06/30/2014 11 :29 AM
Ian, See below - we had escalated it to you, then discussed it over the phone.
Based on our discussion we said we were going to deny it and you agreed. Thanks!
Forwarded by Diane Freundel/PHEAA on 06/30/2014 11 :25 AM -----
Fro Ill l(b)(5) I~(b,.)(5~)~~=~~~

fo "EedloanPSL,E"
<fedLoanPSLE@oheqa.org>
Cc: l(b)(5) 1.l~_(b,,)("'5)==---~J
D:1te 06/10/2014 02:14 PM
S,Jbject RE: American Immigration LawyersAssociation
-----Dri0inal Messaqe-----
From: Jiine Freundci [mailto:dfreu~de~ptcaa.org] 0~ Retalf Of Fed::...oan PSLF
Serit.: Wed11esd~y, Mnv 07, 2814 12:12 PM
To: l'ed~c:,an PSLl'
Cc::: l(b~)(e-5)~~-~~
0
Subject: Re: Ameri:::an Immigration ::...awyers Ac:soeiation
!Ii lan, Thank.s aqa.1n for Lalk..1n9 eHLh K.1m and me Lviay. The d.1s2ussion
really l:elped !
We looked at-. t'.1e Mic,c,ion and c;:Jalc; :Jf t-_l:f-' l\.I::...h and we ck:1't L1i11k Lns
employer q:ual.1f.1es. They ci.ef.1:1.1Lely don' L qual.1Iy .1nde.t Lhe p.1bli2 serv.1ce
tl:ey listed (rubli::: edu:::ation) Upon turther review, v,:e also could:1't tinci.
any indieatio~ that the cmploycec: of the Asc:oeiatio~ :crovicie q·Jalifying
:cublic i:1terec,t_ lnw :,er vices.
(See attached tile: AILA - Mission & Goals.:idt)
From: ~ed-,o~o PSJ,f/pf~Aa

To: l(b)(5) I
Jnt.f-': 05/05/2014 18: 01 l\.M
SubjecL: Public: Ame.t.1can lmmi9.taL.1on La·,1yers AssociaL.1on
Sent Dy: Diane Freundel
. Kb)(6)
!Ii lan, C:ould you please rev.1e-,1 L_--us o:1e.r
(b)(6)
.
b)(6) ?asswc:,rd Le:, Iollc:,w.
I Thanks!
(Sec attached file: American Immigration Lawyers Association.zip)
:Jia:1e L0 .teundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
df.teunde@pheaa.org
Tl:is messo.ge conto.i::-is privileged o.::-id contidentio.l i::-itormation inte::-ided tor

ttc a~ovc addressees only. If you receive ttis message in error please
delf-'t.e ,;;r dec;t_roy t.'.1ic: lllf-'cic:agf-' and/:Jr nt.t.achmf-'nt.c:.
Tl:e sender ot this messo.ge ·,:ill tully :::oopero.te in the :::ivil anci. :::rimino.l
~rosecution of any individual engaging i~ the unaut~orizcci use of t~is
mec;:c;age.
From: FedLoan PSLF

To; FedLoan PSLF
Cc: !(b)(5)
Subject: Public: Re: American lmm1grat1on Lawyers Assoc1at1on
Date: 05/07/201412:12 PM
Attachments: American lmm1oration Lawvers Assoc1at1on.z10
AILA - Mission & Goals.odf
Hi Ian, Thanks again for talking with Kim and me today. The discussion really
helped!
We looked at the Mission and Goals of the AILA and we don't think this employer
qualifies. They definitely don't qualify under the public service they listed (public
education). Upon further review, we also couldn't find any indication that the
employees of the Association provide qualifying public interest law services.
Let us know if you agree/disagree. Thanks!
Diane
FedLoan PSLF---05/06/2014 10:01 :18 AM---Hi Ian, Could you please review this
one. We were going to deny - it's a 501 (c)(6). They indicat
From Fedloan PSLF/PHEAA

To· l(b)(5) I
Date: 05/06/201410:01 AM
S.JbJect Public:AmericanImmigrationLawyersAssociation
Sent by· Diane Freundel
b)(6) Password to follow. Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfreunde@pheaa.org
AILA - l\,fr,smn & Goab
""°"'I lioll> I ~ I ~ I ~ I Ml2l2lli> ~ -

H,·,mr;> Ab,·,u1AILA> t·/i,;,,10,1& Co;:Lo lnfoNet Login
Recent Postings
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Advocacy Resources
Agencies & Liaison Mission Password

Agora
The American Immigration Lawyers Association is the
Shop. Register. Learn. Fcrgot Pc.ss·.voro
national association of immigration lawyers established
Cases & Decisions
to promote justice, advocate for fair and reasonable
Chapters & Commlmities immigration law and policy, advance the quality of SIGNIN
Conferences immigration and nationality law and practice, and lnloN~t Rcgistrat10·1
Featured Topics enhance the professional development of its members. I ou,n ,~ss1sta1·ce
Practice &
Professionalism
Strategic Goals []
Publications 1. Increase member participation in advocacy before Manage Your
Web Resources Congress, the Judiciary, the Federal Agencies, RECENT POmNGS ALERTI
and the media, for immigration-related interests
Membership of our clients and society.
Career Center
o Educate the public about the ways in which U.S. immigration law and
About AILA
policy serves the national interest by reuniting American families,
protecting refugees, & providing U.S. employers with the specialized
skills they need to remain globally competitive.
o Enhance respect for immigration law, and professional recognition of

immigration lawyers, by government, the bar, and society.
o Support AIC's Legal Action Center and educational programming.
2 Increase the level of knowledge and professionalism, and foster the

professional responsibility, of our members.
o Enhance the litigation capabilities of the membership as an important

option to ensure the just administration of our immigration laws.
o Assist members in effectively and competently pursuing their law

practice and enhancing their professional satisfaction.
o Advance the protection of the public by promoting consumer protection

and authorized representation.
o Promote and support delivery of competent, ethical, and lawful

immigration services by lawyers, authorized accredited representatives,
and pro bono programs.
o Encourage and facilitate member participation in, and support for, pro
bona services and programs.
http://www.aila.org/contcnt/dcfault.aspx~docict= l 2130[ 5/712014 11:48: 13 AMI

Copyriglll <<) 1993-2014, Americar1 lmmigratior1 Lawyers Associaliori.

Suite 300, 1331 G Street NW Washingtor1. DC 20005
Copyright & Rop11·1t Policy
Co·1ta~t Us
http://www.aila.org/contcnt/dcfault.aspx~docict= l 2130[ 5/7/2014 11:48: 13 AMI

From: Kimberly A Myers

To; Brittany L Wagner
Cc: FedLoan PSLF; FL$ PSLF Supervisor Review
Subject: Re: Fw: [external]Borrower Information Request
Date: 01/30/2017 09:58 AM
Attachments: Borrower lnformat1on Request.docx
Borrower Information Request.zip
Thanks Brittany! I will let FSA know, at least for that particular borrower, we don't
have anything.
As soon as you can pull the rest of the information for the other borrowers and get it
to me, I would appreciate it. Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
BrittanyL Wagner---01/30/2017
09:43:53AM---GoodMorningKim,Wedo not
have a record for Ms. ~ I have searched up and down and have even w
Frorn Brittany L Wagner/AES
To Fedloan PSLF/PHEAA@PHEAA
Cc: FLS PSLF Supervisor Review/Fedloan Servicing@PHEAA, Kimberly A
Myers/PHEAA@pheaa
Date 01/30/2017 09:43 AM
SJbject· Re: Fw: [external]Borrower Information Request
Good Morning Kim,
We do not have a record for Ms. ~ I have searched up and down and have even
went as far as looking for the American Immigration Lawyers Association. The only
borrower that returned for that employer was a Laura Lynch.
Brittany L Wagner
FedLoan Servicing Operational Support I PHEAA
FedLoan PSLF---01/27/2017 03:57:31 PM---Hi Brittany! We just received the

belowrequestfrom FSAregardinginformation. I attemptedto lac
lrom: Fedloan PSLF/PHEAA
To Brittany L Wagner/AES@PHEAA
Cc FLS PSLF Supervisor Review/Fedloan Servicing@PHEAA
Date: 01/27/2017 03:57 PM
S.JbJect Fw: [external]Borrower Information Request
Hi Brittany! We just received the below request from FSA regarding information.
attempted to locate the SSN's, but could not find one for the second individual,
maybe you can locate something through a query? They are in the attached
document. If you locate the SSN, please let me know.
I can pull the ECFsand disputes from FileNet. Can you or have someone else pull
the rest of the information?
Thanks!
Forwarded by Kimberly A Myers/PHEAA on 01/27/2017 03:53 PM-----
From l(b)(5) I (b)(5)

7oa~o~P~SLcF~@~p"he~a~a-c"_org·>
To· FedLoan PSLF<'Fc"ediiL
Cc: "Foss, Ian" <Ian.Foss ed. ov> "Battle, Cynthia"
<Cynthia.Battle@ed.gov>, (b)(5) l(b)(5)
[)ate· 01/27/2017 03:22 PM ~~-----
S"1bJcct: [external]Borrower Information Request
Hi Kim,
Could you provide all PSLFinformation (ECFs on record, disputes and

correspondence), call logs, emails, and the servicing history associated with the
attached borrowers. Unfortunately, we only have the borrower names. Please
let me know if you need additional information to identify the borrowers.
PW to follow.
Thanks,
Taneka
61
crb_l(_
____ ~1vietnam Veterans for America
1-
liliiill:Jl(b)(6J American Immigration Lawyers Association Could not locate
(b)(6) ABA
From: Gabriel Hunt

To; Andrea R Aunkst
Cc: Fred Wagenmann: Guzman E Rodriguez
Subject: Re: Fw: Retraction Guidance
Date: 04/12/2017 05:26 PM
Andee, Guz,
I created a PCN in quality center for the additional scope of processing applications
and ECFsfor forgiveness on the web. Please continue to use the 15601 support task
in planview to track your time.
Defect ID: 1000 PSLF Forgiveness - Processing Applications and ECFs on the Web
Gabe Hunt
Information Technology
AES/PHEAA
(717) 720-3607
Andrea R Aunkst---04/10/2017 03:07:47 PM---Gabe/Fred Ai our forgiveness

meetingwith the businesslastweek,we learnedthat there is a special
From· Andrea R Aunkst/PHEAA
To: Gabriel Hunt/AES@pheaa, Fred Wagenmann/PHEAA@pheaa
Cc Guzman E Rodriguez/AES@pheaa
[)ate· 04/10/2017 03:07 PM
S"ibJcct: Fw: Retraction Guidance
Gabe/Fred
At our forgiveness meeting with the business last week, we learned that there is a
special letter for retractions for ECFs - borrower status changes from approved to
denied for employer not qualified. For CR15601, we have the standard
approval/denial letter being generated anytime the status of an ECF changes. In
January, FSA mandated some specific information for the retraction letter that we
don't already have available in letter writer so at this point the BU will have to handle
the letter manually. We still need to make a change for CR15601 to suppress the
standard letter trigger for retractions.
I assume someone needs to log a PCN for this? I'm not sure who? Does it need to
go through estimation?
Please advise.
Thanks!
Andrea (Andee) Aunkst

Customer Experience & Usability (CEU)
717.720.3541
Forwarded by Andrea R Aunkst/PHEAA on 04/10/2017 02:51 PM-----
From Andrea R Aunkst/PHEAA
To BrittanyL Wagner/AES@PHEAA
Cc Guzman E Rodriguez/AES@pheaa, MelindaA. Bishop/AES@pheaa,
PatrickA Phelan/AES@pheaa,Gabriel Hunt/AES@pheaa
D:1te 04/07/201701:15PM
S,Jbject Re: RetractionGuidance
Hi Brittany
After reviewing this email chain, I wanted to share these thoughts ...
With CR015601, we have created a Peer Review step that's expected to

reduce retractions.
When a processor hits the submit button, the system checks for existing processed
ECFswith a conflicting employer eligibility decision. If a conflict is identified, a peer
reviewer will review the processor's decision on the ECF and either (1) make a
correction to the decision or (2) verify that the decision is correct. Making the
correction will prevent the conflict from happening. If the peer reviewer agrees wit
the processors decision, then a conflict will occur. This would indicate that something
could be incorrect on a previous ECFthat has already been communicated to the
borrower.There's still a chancethat an incorrectdecisioncouldbe made on the first
ECFfor an employer and wouldn't be caught until a correct decision is made and
triggers the Peer Review and subsequently the Conflicting Decision. However, I think
it's safe to assume the peer review process will dramatically reduce the number of
retractions,as we will catch processorerrors before the borrower is informedof the
decision.
Employer-level decisions are automatically applied across ECFs with

employment periods for the affected time frame.
This happens happens when an employer review is completed by a
supervisor/compliance. As long as any change affecting an eligible period is
approved by FSA before it is updated in the employer record, I don't believe this is an
issue, in fact I would think it will prevent creation of conflicts as it will happen without
manual intervention. The only issue here is that we do not update ECFsprocessed
on Compass because the EIN is not unique and will not have the system assigned
unique identifier that is available when processed on the through the web. A query
will have to run to identify them, unless some kind of clean up can be done to create
the unique id for ECFsprocessed on Compass
No Restrictions on the changes to post-processing changes

The web interface is currently designed to allow any change to an ECF, including
employer eligibility decision. There are currently no system restrictions. Also, a
processor working the Decision Conflict report has the ability to change an employer
eligibility decision - there is a UI specifically for this. I'm not sure if this something
you feel comfortable handling procedurally or if you would want to implement a
change here to force a compliancereview if a processorwants to change a decision
form eligible to ineligible or otherwise modify the design.
Existing feature for escalation to FSA

We already have a feature to allow a compliance user to escalate a review to FSA.
Although this feature will not perform the physical escalation, it does place the review
in a pending FSA review status so that staff have visibility into what's in their court
vs. FSAs court and will facilitate follow-up and monitoring for escalated items.
Reaction Letter
I don't believe we requested an automated letter for retraction. I believe we are
triggering the basic Approval/ Denial letters when the status changes. Since the
change is applied automatically in some cases, I think we need Mindy to create a new
letter or modify one of the existing letters.
Let me know if you want to discuss.
Thanks!
Andrea (Andee) Aunkst

Customer Experience & Usability (CEU)
717.720.3541
BrittanyL Wagner---04/07/2017
11:49:14AM---Hereis the guidancethat was
providedby FSAon the retractionof employers.
Frorn Brittany L Wagner/AES
To Patrick A Phelan/AES@PHEAA,Melinda A. Bishop/AES@PHEAA,Andrea
R Aunkst/PHEAA@pheaa
Cc: Guzman E Rodriguez/AES@pheaa
Date 04/07/201711:49AM
SJbject· Retraction Guidance
Here is the guidance that was provided by FSA on the retraction of employers.
Brittany L Wagner
Fedloan Servicing - Operational Support I PHEAA
Forwarded by Brittany L Wagner/AES on 04/07/2017 11 :45 AM -
From· Fedloan PSLF/PHEAA

To: FLS PSLF Supervisor Review/Fedloan Servicing@PHEAA
Cc Brenda Gossard/PHEAA@pheaa, Jody Teter/PHEAA@pheaa, Kayce R
Gregory/AES@PHEAA, Brittany L Wagner/AES@PHEAA, Melissa L
Shoemaker/AES@PHEAA, Matthew J Eshelman/AES@PHEAA, Diane
Freundel/PHEAA@pheaa
[)ate· 11/16/201610:08 AM
S"ibJcct: Fw: [external]RE: RE: Re: Re: Re: Re: PSLF - American Bar
Association
employer in error without reviewingprior guidance (e.g. Compliancedenied an
account.
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Forwarded by Kimberly A Myers/PHEAA on 11/16/2016 09:16 AM
From· l(b)(5) I (b)(5)

To: FedLoan PSLF<'F""ed"L~,-a~,P~S~L~F@~ph~e_a_a-.o~,g>
Cc: "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel
<dfreunde@pheaa.org> "Utz Jon" <Jon.Utz@ed.gov>, "Foss, Ian"
<lan.Foss@ed.gov>, l(b)(5) I
l(b)(5) I"Odom,
Christian" <Christian.Odom@ed.gov>
Date 11/15/2016 04:38 PM
SJbject· [external]RE: RE: Re: Re: Re: Re: PSLF - American Bar Association
111l(im,
Thank you again for providing details to us regarding the retraction process Moving
forward, FSA would like Lo review arid approve all relraclior1 cases rel aled lo
employment prior to servirer proressing
We envision that the process will be similar to the employer escalations currently
forwarded Lo FSA lor review Effecl1ve irnrnedialely, we would like lo receive lhe
following information for e,1rh rase v1,1the PSLF1nbox L(b_)(~51
______ ~

Number of borrowers impacted;
Dale ol lhe oldesl approval,
A rnpy of the retr;iction letter;
[CF(s), and
any research that FedLoan has already conducted on the employer.
Since rnar1y of lhe:,e relraclions are lirne-serhilive, FSA will make every efforl lo
provide a decision h;ick to Fedlo,1n l.'Jithin 3-5 business d,1ys
Please let us know if you have concerns with this request or if you need additional
inlorrnalion.
Kind rf'gards,
Taneka
From: l(bl(51 I
To: FedLoan PSLF; l(bl(51 I
Thank you, Kim This is really hf'lpful information We will discuss on this s1df' ;ind l.'Jill
get back to you
Kind Regards,
Tanek;i
From: Kimberly A Myers [ ~] On Behalf 01 FedLoan PSLF

To: l(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; 'FedLoan PSLF'; Utz, Jon;
Tiongquico,Rene
Hi Tankea! Again, I apologize for the delay. I wanted to ensure I

provided you with accurate details. Overall it appears the Business Unit
retracted a total of 320 employers, with a breakdown as follows: 4 in
2012, 37 in 2013, 123 in 2014, 64 in 2015 and 92 in 2016. These
numbers also include the employers that you are aware of. I know the
Business Unit performed some clean-ups (specifically in 2014 and
2016) to identify any employers who might have been approved in
error.
Based on internal reviews (those outside of the employers we escalated

to FSA), the breakdown of retractions is as follows: 243 were deemed
for-profit and 49 were deemed not-for-profit but not providing a

qualifyingpublicservice. There were some other miscellaneous
retractions (e.g. we retracted the approval to request additional
clarifying information due to conflicting information received via a later
ECF, the borrower was determined to be a volunteer, etc). Just to note,
some of the retractionswere due to the borrowerprovidinginaccurate
information on the initial ECF which wasn't identified until he/she
submitted a subsequent ECF with conflicting information.
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
f-10111 l{b)(5) I<publicservice@ed.gov>

Io '"Fedloan PSLF"' <FedLoanPSLF@pheaa.org>, l(b)(5) I<publicservice@ed.gov>
Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>. Diane Freundel <dfreunde@pheaa org>, "Utz, Jon"
<Jon.Utz@ed.gov>, "Tiongquico, Rene" <Rene.Tiongguico@ed.gov>
Date 10/17/2016 03:52 PM
Sub1ect [external]RE: Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
I Just wanted to follow-up to find out if you were able to find out the average
number of retractions that are issued by PHEAA.
Thanks,
Taneka

Hi Kim,
Do you have an idea of the average number of retractions that are issued by
PHEAAon a yearly basis? Additionally, would you know about how many of
those retractions are for employers who were non-profit that we determined
did not provide a qualifying service and those who PHEAAjust determined
were for-profit?
Tentatively, I would say that we would like to be aware of all retractions,

especially in the instance where the retraction is going out years after the
borrower's employment is approved, and be able to review the letters before
going out to borrowers We'll wait to hear about the volume that you
anticipate we would need to review before making any decisions
Thanks,
Taneka
Hi Taneka! Historically, if an employer retraction is because of

changing guidance, etc, we will escalate those to you before taking
action. However, if we discoverinternallythat an employerwas
approved in error by a processor (e.g. employer was accidentally
approved but it was always for-profit), we will take care of those
internally and not escalate. Based on your wording below, would you
now expect these situations to be routed to you first before we take
action, even though we know the approval an obvious error?
We can definitely forward the retraction letter to you before they are
sent to the borrower. Just for our knowledge, would you expect to have
a quick turnaroundin reviewingthese letters so that we can get them
out to the borroweras soon as possible?
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
f-10111 l{b)(5) li(b)(5)

Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>. Diane Freundel <dfreunde@pheaa.org>, "Utz, Jon"
<Jon.Utz@ed.gov>, "Tiongquico, Rene" <Rene.Tiongquico@ed.gov>. "Chialastri, Taneka"
<Taneka. Ch1a1astr1@ed.gov>
D,1te 10/12/201610:11 AM
Suhw:;t [external]Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
I believe this already occurs, but wanted to confirm if all retractions of

qualifying employment for PSLFare routed to FSAfor review? If not, we would
like to request that in the rare instance PHEAAbelieves we need to retract an
approval FSAis notified through this mailbox so that we may review the
circumstances of the retraction.
Moving forward, we would also like to review a copy of the retraction letter(s)
before they are sent to the borrower regarding their qualifying employment.
On this end, we are in the early stages of discussing ways that FSAcan improve
StudentAid.gov and other outlets to increase transparency regarding the PSLF
process and eligiblity for non-501(c)(3) employers providing qualifying public
services. I'll make sure to provide PHEAAwith an update as more information is
available.
Kind Regards,
Taneka

To: i(b1(51 I
Cc: Battle, Cynthia; Diane Freundel; Fed Loan PSLF; Utz, Jon; Tiongquico, Rene;
Chialastri, Taneka
Hi Taneka! You are correct in you assumption for the retraction tab.
The processed date is the date it was approved. Essentially it all occurs
in one step (the ECF is processed as an approval).
With the retraction letters, we had previously advised that the Business
Unit that they need to include more detail. Previously it was very
generic (it just basically stated that the employer was retracted, but
didn't give much explanation as to why). It has gotten better, but we can
certainly work more with the Business Unit to "beef" up the denial
letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
From l(b)(5) ll(b)(5)
Tr: FedLoan PSLF <FedLoanPSLF@pheaa QrQ>

Cc "Battle, Cynthia" <Cynthia.Battle@ed.gov>, Diane Freundel <dlreunde@pheaa.org>,
"Tiongquico, Rene" <Rene.T1ongciuico@ed.gov>, "Chialastri, Taneka" <Taneka.Ch1alastri@ed.gov>,
··utz, Jon" <Jon.Utz@ed.gov>, l(b)(5) I<publicservice@ed.gov>
Date 10/07/2016 01 :47 PM
Suhw:;t [external]Re: Re: Re: PSLF - American Bar Association
Hi Kim,
Quick question for the retraction tab - Is the processed column date the date
that the borrower's ECFwas approved?
In regards to the retraction letter - I know we previously discussed PHEAA

providing more detail in the retraction letter and I recall the Business Unit
making a few changes; however, I think we may need to revisit the way the
retraction letters are drafted to ensure that we are being as transparent as
possible to borrowers who are being informed that a previously qualified
employer is no longer eligible. I'm going through emails and noticed the
retraction letter is similar for borrowers employed with Students First so
wanted to make sure that we make every effort to make sure borrowers are
informed.
Thank you,
Taneka

To: i(b1(51 I
Cc: Battle, Cynthia; Diane Freundel; FedLoan PSLF;Tiongquico, Rene; Chialastri,
Taneka
Subject: Re: Re: Re: PSLF- American Bar Association
Hi Taneka! I was able to pull together the information you requested

(no pressure for a mid-Friday) : )
I attached a spreadsheet which provides the borrowers whose ECFs

were approved then retracted, as well as the borrowers whose ECFs
were denied outright. The spreadsheet has two tabs with each cohort of
borrower.
For the borrower whose approval was retracted after 45 months, I
included the letters we have on record. There is one system generated

denial letter, one system generated approval letter, and the manual
retraction letter. Just a head's up on the system generated denial
letter. His ECF was originally not complete, so the denial is for missing
information. He returned another, complete, ECF which is the one that
was approved.
If there is anything else you need, please do not hesitate to ask.

Password to follow. Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
From -~If
~!(b~)(5L) Lb_)(6_1
_____ ~
Cc Diane Freundel <dlreunde@pheaa.org>, "Chialastri, Taneka" <Taneka.Ch1alastr1@ed.gov>,
"Tiongquico, Rene" <Rene.T1ongciuico@ed.gov>, "Battle, Cynthia" <Cynth1a.Battle@ed.gov>, Fedloan
PSLF <FedLoanPSLF@pheaa.org>, l{b)(5) I l(b)(6)
Date 10/07/201610:28AM L._________ J
[external]Re: Re: PSLF - American Bar Association
Hi Kim,
Would you be able to provide detailed information on the borrowers whose

qualifying employment was was outright denied for the American Bar
Association as well as the borrowers who were originally approved and
received retractions to date.
If possible, we need a secure file listing the borrowers names, SSN, Employer
EIN, the date the ECFwas received, Processed, Approved, Denied, Retracted
,and Notes (if applicable). Additionally, we would also like to see a few
approval, denial and retraction letters for the borrower who had their approval
denied after 45 months.
My apologies for having to request this on a Friday but if your team can pull
this information as soon as possible we would appreciate it. Please let me know
if you have concerns.
Thanks,
Taneka
From: Kimberly A Myers <kmyers@pheaa.org>

To: Foss, Ian
Hi Ian! Attached is a redacted copy of the ECF and corresponding

retraction letter to the borrower. Thanks!
Kimberly A Myers
ComplianceServices
kmyers@pheaa.org
(717) 720-2630
To Kimberly A Myers <kmyers@pheaa.org>
Cc Diane Freundel <dfreunde@pheaa.org>, "Chialastri, Taneka'" <Taneka.Chialastri@ed.gov>
Date 04/13/2016 08:42 AM
Can we get a copy of one of the retraction letters (redacted) and also confirm
that the organization claimed to be a non-501(c)(3) not-for-profit that was
claiming to provide public interest legal services. I realize that some may have
come in as being from the 501(c)(3}, even if it were ultimately determined that
the borrower didn't work there. So I'm asking about the ones that came in
directly from the ABA.
Hi Ian!
Based on the query the Business Unit performed, there were 9

borrowers who were denied outright and a total of 19 that received
retraction letters. Of the 19 who received retractions letter, 14 were
picked up in this most recent query the Business Unit ran.
The longest timeframe from the date the borrower was originally
approved to the date retracted was 45 months. However, one thing to
note for that particular borrower, the Business Unit only retracted about
1O months of employment (from 8/2011 to 5/2012).
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Frrnn "Foss, Ian" <Ian Foss@ed.gov>
Io ""'Kimberly A Myers"'" <kmyers@pheaa.org>
Cc Diane Freundel <dfreunde@pheaa org>, "Chialastri, Taneka" <Taneka Ch1alastri@ed gov>
Dale 04/08/2016 02:56 PM

Sub1ect [external]RE: RE: PSLF - American Bar Association
Can you give me a sense of how many borrowers received a retraction

regarding the ABA and how many received outright denials? Also, for those
retracted, how long after the approval did the retraction go out (for the
borrower for whom it was the longest)?

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we

had forwardedany other "Bar"or "Bar Associations"for review.
Although we didn't escalate the employer, I know you also initially made
a determinationon the AmericanImmigrationLawyersAssociation
(which Jeff Baker also drafted a letter to the borrower that Taneka
shared with us).
I know in the beginningwe were strugglingwith associationsin general

and specifically organizations that would qualify under the "public
interest legal services" category. At one point, I know we had talked
through it over the phone, which gave us a clearer understanding of this
category. Once we grasped what organization would/would not qualify
under this category, we internally made the decisions and only
In regards to the American Bar Association, we made the decision

internally that they do not qualify and provided this guidance to the
Business Unit. As we received ECFs from borrowers employed by the
AmericanBar Association,we were denying.
I know in some instancesthere were borrowerswho were certifiedas

working in a qualifying arm of the American Bar Association (e.g.
American Bar Association Fund for Justice and Education under the EIN
36-6110299). If we had a reason to question it, we would request the
borrower's W-2 to confirm who actually paid the borrower. In most
instances, the borrower turned out to be employed by the American Bar
Association directly under the EIN 36-0723150. In light of your decision
on ACLU, we now have reason to question this further.
We were recentlyescalatedan accountfor the AmericanBar

Association where the previous approval had not been retracted. As a
result, the Business Unit ran a query to identify and clean up those
borrowerswho may have been approvedunderthe AmericanBar
Association in the past who should not have been. This is most likely
where the retractionof the previousapprovalcame from.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Fm111 "Chialastri. Taneka"< Taneka.Chialastri@ed.gov>

To "Foss, Ian" <lan.Foss@ed.gov>, Diane Freundel <dlreunde@pheaa.org>, "'Kimberly A Myers"'
<kmyers@pheaa org>
Dale 04/08/201612:02 PM
Sub1oct [external]RE: PSLF - American Bar Association
Hi Ian,
I don't show anything on record for the American Bar Association I only have
documentation of decisions made regarding the King County Bar Association,
Bar Association of San Francisco, State Bar of Wisconsin, and the District of
Columbia Bar.
Thanks,
Taneka
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLFand the American
Bar Association? We just got a letter saying we approved them and then
retracted it several years later. I'm not finding record that I worked on it
Thanks,
Ian
above addressees only. If you receive this message in eITor please delete or
Code:PHEAA
From: Matthew J Est1elman

To; Kimberly A Myers
Subject: Re: IZtiiill
liliifili]denied ECF- AILA not qualify
Date: 12/21/2016 09:15 AM
Thank you very much!
Matt Eshelman
Program Strategy and Support Analyst
FedLoan Servicing I PHEAA
PO Box 1845
717-720-2431
meshelma@pheaa.org
KimberlyA Myers---12I21I2016 08:54:12AM---HiMatt! I agreethat this borrower

shouldnot be referredbackto her currentloanservicer. We a
From· Kimberly A Myers/PHEAA
To: Matthew J Eshelman/AES@PHEAA
Cc: Mikell L Czerrnendy/AES@PHEAA, Melissa L Shoemaker/AES@PHEAA,
Jessica M Nieves/AES@PHEAA, Wilbert Pless 111/AES@PHEAA,Diane
Freundel/PHEAA@pheaa, Brenda Gossard/PHEAA@pheaa, Jody
Teter/PHEAA@pheaa, Brittany L Wagner/AES@PHEAA, Corey
Detar/AES@PHEAA, Robert G Cameron/AES@PHEAA, Joyce
Zaleski/AES@PHEAA
D:1te 12/21/2016 O~M
S,Jbject Re: lili:i1fill.
~ denied ECF - AILA not qualify
Hi Matt! I agree that this borrower should not be referred back to her current loan
servicer. We are the sole PSLF servicer, so any complaints regarding the program or
decisions rendered should remain with Fedloan Servicing.
This emplo er American Immigration Lawyers Association and specifically this

borrower (bl(6 1 !(b1(
61 I
was escalated to Compliance in April 2014. Due to the
specific nature of this organization we, in turn, escalated the employer to FSA. In
June 2014, FSA made a decision that while this employer is not-for-profit, 501 (c)(6),
they do not provide a qualifying public service.
There was another borrower, Ms.fb1( 61 Kl'm not sure if she has loans with us or ever
submitted an ECF), with who FSA corresponded directly, advising of the ineligibility of
the AILA. I attached this letter, dated December 10, 2014, for your reference. This
letter specifically details the Department's stance on this employer. Specifically, in
order to qualify for PSLF as a private not-for-profit provide public interest legal
services, the organization must provide legal services that are funded in whole or in
part by a local, State, Federal, or Tribal government. Employees of AILA do not
provide public interest legal services; rather, such services are provided by the AILA's
member attorneys. This is typical of most associations, the employees of the
association do not perform the services, but members do.
(b)(5)
b)(5)
Thanks!
[attachment "FSA letter to borrower.pd!" deleted by Matthew J Eshelman/AES]
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
MatthewJ Eshelman---12I20I2016
05:23:17PM---Mikell.Becausethis is a
complaint regarding our determination whether this borrower's employer is
From Matthew J Eshelman/AES

To· Kimberly A Myers/PHEAA@pheaa, Mikell L Czermendy/AES@PHEAA
Cc: Melissa L Shoemaker/AES@PHEAA, Jessica M Nieves/AES@PHEAA,
Wilbert Pless 111/AES@PHEAA,Diane Freundel/PHEAA@pheaa, Brenda
Gossard/PHEAA@pheaa, Jody Teter/PHEAA@pheaa, Brittany L
Wagner/AES@PHEAA
D:1te 12/20/2016 O~M
SJbject· Re: liliiffill
~ denied ECF - AILA not qualify
Mikell, Because this is a complaint regarding our determination whether this borrower's
employer is a public service organization, we should not refer her back to her current loan
servicer. For the same reason, we won't be able to say it's simply a policy issue -- even
though her concern does ultimately center on the regs -- at least not until we've explained
the regulations which apply in greater detail than we already have.
b)(5)
Copying PSLFSupes for visibility. Please see attachments below.
Thank you!
Matt Eshelman
PO Box 1845
717-720-2431
meshelma@pheaa.org
FedLoanBorrowerAdvocate---12I20I2016
01:53:33PM---Good
afternoonMatt, I
have something of an odd situation here. This borrower submitted a CFPBcompl
From Fedloan Borrower Advocate/Fedloan Servicing
To· Matthew J Eshelman/AES@PHEAA
Cc: Wilbert Pless III/AES@PHEAA, Jessica M Nieves/AES@PHEAA
D:1te 12/20/2016 01 :53 PM
I
SJbject· Fw: [external]Re: TO: lilii@l l(b)(6) RE: You Student Loan Account
with Fedloan Servicing (Policy Issue - No Loans with FLS)
Sent by Mikell L Czermendy
Good afternoon Matt,
I have something of an odd situation here. This borrower submitted a CFPBcomplaint

against us, however their loans are not actually with us, they're with Nelnet. The
borrower was responded to advising of this, and providing Nelnet's contact
information, however, she followed up with separately with the email I have copied
below.
=cl I - CFPB Inquiry.pd!" deleted by Matthew J Eshelman/AES]

6~1_,,..,sl(b"'l(6
[attachment '--(b-1(
[attachment (bl( 61 (bl( 61 PSLFApplication.pdf" deleted by Matthew J Eshelman/AES]
[attachment
"12.10.2014+Kate+ Voigt+Received+PSLF+Response+ from+ lan+Foss.pdf" deleted
by Matthew J Eshelman/AES]
b)(5)
----- Forwarded by Mikell L Czermendy/AES on 12/20/2016 01 :48 PM -
lrom: I
liliifilill(b)(6) <llynch111@gmail.com>
To Fedloan Borrower Advocate
<FedLoanBorrowerAdvocate@myfedloan.org>
Date: 11/23/201609:41 AM
S.JbJect [external]Re: TO: lili:ifilll I
l(b)(6) RE: You Student Loan Account with
Fedloan Servicing
Hi Mikell-
I also wanted to follow up with about your following statement:
"It is also important to note that, as a sen,icer rdfederal student loans

assigned b.v the U.S. Department rdEducation, we do not have the
authority to determine the necessary qua!Uications for an emplo:rer to be
considered eligible in regard to the Public Service Loan Forgiveness
(PLSF)program. Federal Government regulation stipulates •,vhich
employers."
I would like to formally request that my complaint is forwarded to entity

with the authority to determine whether an employer is considered
eligible in regard to the Public Service Loan Forgiveness (PSLF)
program.
Please let me know if you have any follow up questions.
Best regards,
~
(b)(6)
On Tue, Nov 8. 20 l 6 at 9:42 AM. FedLoan Borrower Advocate

<F Lo nB rrow rA vo m ·f l nor > wrote:
Good afternoon Ms. (bl( 6 1
My name is Mikell. I am a Borrower Experience Advocate with

Fedloan Servicingand your case has been assignedto me. We are in
receipt of your complaint through the Consumer Financial Protection
Bureau (CFPB)and have reviewed your concern. However we have
unfortunately been unable to locate an account for you in our system
using the demographic information you provided through the CFPB.
Can you please provide us with your FedLoan Servicing account

number? You can find your accountnumber on any billingor account
statements we send to you. If you are unable to locate your account
number, you may provide us with your full Social Security number
instead.
You may provide us this information by simply replying to this email,

or by reachingout to me usingthe contact informationprovided in my
signature below.
It is also important to note that, as a servicer of federal student loans

assigned by the U.S. Department of Education, we do not have the
authority to determine the necessary qualifications for an employer to
be considered eligible in regard to the Public Service Loan Forgiveness
(PLSF) program. Federal Government regulation stipulates which
employers
We appreciate your concerns and look forward to assisting you. Thank

you, and have a great rest of your day.
Regards,
Mikell Czermendy
FedLoan Servicing I PHEAA
PO Box 1845
FedLoanBorrowerAdvocate@MyFedLoan.org
This message contains privileged and confidential information intended for

the above addressees only. If you receive this message in error please delete
or destroy this message and/or attachments.
prosecution of any individual engaging in the unauthorized use of this
message.
Code:PHEAA
Fw: CFPB Case# 160928-000265 - [iiiillJ ~ (Unknown) - ((FD))

VIP Escalated Mikell L Czermendy 10/04/2016 12:55 PM
Wilbert Pless Ill
Jessica M Nieves, VIP Escalated
Hi Mikell,
Fed Loan Inquiry - After a review, we are unable to locate account for l(bl(6l
l(bl(6l I
Please attempt to locate this account.
NAME:N/A
ACCT#: N/A
Wilbert Pless Ill

Fedloan Servicing
----- Forwarded by Wilbert Pless Ill/AES on 10104/2016 10.34 AM-----
From Jessica M Nieves/AES

To VIP Escalated/AES@PHEAA
Cc Donald Cameron/PHEAA@pheaa, Wilbert Pless 111/AES@PHEAA
Date 09/29/2016 09:46 AM
SulJwct CFPB Case# 160928-000265 -lili:i:filiJ I
l(b)(6) (Unknown)- ((FD))
What happened
Product:
Issue:
Please note that this case is affiliated with [Case number: 160826-001442]. I am submitting this
complaint due to my experience with Fedloan Servicing concerning the PSLF program. In 2012.
my colleague contacted the Department of Education inquiring as to whether her 50 I (c)(6)
employer. the American Immigration Lawyers Association (AILA). was a qualifying
organization for purposes of PSLF. The Department of Education affirmed that the organization
was a qualifying organization under PSLF. When I submitted my PSLF certification to Fedloan
Servicing in March of 2014, I was denied by Fed loan Servicing without explanation. The letter
stated, "Organization does not qualify." Fedloan Servicing subsequently revoked my colleague's
PSLF eligibility claiming that our 50l(c)(6) organization was not a "qualifying organization" for
purposes of PSLF. I requested supervisory review of my personal application but the only
information that I received back from Fedloan Servicing is that "organization does not qualify."
Additionally. one of Fedloan Servicing employees told me that she was unaware of any 50 I (c)(6)
organizations that were approved as "qualifying organizations" under 34 CFR Section 685.2 l 9(b)
for purposes of PSLF. This is denial is contrary to the regulations because my 501(c)(6)
organization clearly provides public education and meets the requirements of a "public service
organization" as defined by the regulations. The Department states in the proposed rule (pg.
37705, http://www.gpo.gov/fdsys/pkg/FR-2008-07-0 l/pdf/E8-14140.pdf), that the statutory
definition of "public service job" is meant to include "certain non-profit organizations that are not
qualified under 50 l (c )(3) of the IRC, but that meet the other statutory requirements and qualify
as public service employers under HEA." Congress clearly defined "public service job definition"
in the HEA (http://www.gpo.gov/fdsys/pkg/PLA W-l 10publ315/html/PLA W-11 0publ315.htm)
to include both "public education" and "public interest law services."
Attachment
File Attachment
KbJ(6) jPSLFApplication.pdf (882.97 KB) ~PSLFApplication.pdf

12.10.2014 Kate Voigt Received PSLF Response from Ian Foss.pdf (704.42 KB)
lml
12.10 .2014+Kate+ Voigt+ Received+PSLF +Response+from+lan+F oss. pdf
Desired resolution
Desired resolution:
The fair resolution is for Fedloan Servicing to reinstate my organization's eligibility as a
"qualifying organization" for purposes of PSLF.
First name:
~
Last name:
~
Street:
City:
Washington
State:
DC
ZIP Code:
20036
Country:
United States
Yes
No
No

No
Product information
Name on account:
~~
~r_1(s_1
____ ~rmber:
Company name:
Fedloan Servicing
State:
DC
Case Details
Case number:
160928-000265
Company status:
Sent to company
Sent to company:
09/28/2016 09:51
Respond by:
10/13/2016
Thank you,
Jessica Nieves
717-720-2414
From: Brittany L Wagner

To: Kimberly A Myers
Cc: MaJlhewI 0 shelman:
H1kell
I -~zermendv:
Me11w1
I "hoemaker:lessi"aH Nieves-
Wilbert"lessIll: Dianefre11ndeL
BrendaGossard=~
Teter; Corey Detar: Robert G Cameron: Joyce Zalesk,
Subject: Re: libill lilijj]]
denied ECF AILA not qualify
Date: 12121/2016 01 ·22 PM
Attachments: 0
SAlet rt borr wer df
- Cf-P8 lnqu,ry Ddt
/h)/R) LFA 11'"1 11. jf
1210.2014 (b)(6) Re e1ved+PSLF+Re on e+fr m+I n+F df
Hi Kim,
The only results on our system for AILA is for Ms. ~
SJL FFDE E~IL.2_P5'·._El,1F'_I--ST

BF_PSV_FGV_SSN IM_EMP IF_EMP_BN BC_BR_ECF_STA BD_BR_ECF
_STA
l(b)(6l ;.J.IE" •:;.·~ Ir-nIIGR;.TIJ'~ ~ ·,'YERS.~ss·:,: ;.11:Jr, J
Please let me know if you have any questions.
Brittany L Wagner
FedLoan Servicing Operational Support I PHEAA
D: 717.720.1965 I Bwagoer@aessuccess.org
Kimberly A Myers 12/21/2016 08:54:12 AM Hi Matt! I agree that this borrower should not be
referred back to her current loan servicer. We a
From: Kimberly A Myers/PHEAA
To: Matthew J Eshelman/AES@PHEAA
c·__ Mikell L Czermendy/AES@PHEAA, Melissa L Shoemaker/AES@PHEAA. Jessica M
N1eves/AES@PHEAA,Wilbert Pless III/AES@PHEAA, Diane Freundel/PHEAA@pheaa, Brenda
Gossard/PHEAA@pheaa. Jody Teter/PHEAA@pheaa, Brittany L Wagner/AES@PHEAA, Corey
Detar/AES@PHEAA, Robert G Cameron/AES@PHEAA, Joyce Zalesk1/AES@PHEAA
DJl-2: 12/21/a!l.1.!i.~M
~JbJcct: Re: llb.li]J ID2.lifiljdenied ECF - AILA not qualify
Hi Matt! I agree that this borrower should not be referred back to her current loan servicer. We are
the sole PSLF servicer, so any complaints regarding the program or decisions rendered should remain
with Fedloan Servicing.
This employer, American Immigration Lawyers Association and specifically this borrower~ l(b)(6l I
was escalated to Compliance in April 2014. Due to the specific nature of this organization we, in turn,
escalated the employer to FSA. In June 2014, FSA made a decision that while this employer is not-for-
profit, 501 (c)(6), they do not provide a qualifying public service.
There was another borrower, Ms.~( I'm not sure if she has loans with us or ever submitted an
ECF), with who FSA corresponded directly, advising of the ineligibility of the AILA. I attached this
letter, dated December 10, 2014, for your reference. This letter specifically details the Department's
stance on this employer. Specifically, in order to qualify tor PSLFas a private not-for-profit provide
public interest legal services, the organization must provide legal services that are funded in whole or
in part by a local, State, Federal, or Tribal government. Employees of AILA do not provide public
interest legal services; rather, such services are provided by the AILA's member attorneys. This is
typical of most associations, the employees of the association do not perform the services, but
members do.
(b)(5)
is more concerning is that there was a decision already made for this employer.
Brittany - would you run a query of this organization to determine all borrower's processed. For
ease, the EIN is 23-7085097.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pheaa.org
(717) 720-2630
Matthew J Eshelman---12/20/2016 05:23:17 PM---Mikell, Because this is a complaint regarding our

determination whether this borrower's employer is
I 1011, Matthew J Eshelman/AES

lo· Kimberly A Myers/PHEAA@pheaa. Mikell L Crnrmendy/AES@PHEAA
',.. Melissa L Shoemaker/AES@PHEAA, Jessica M Nieves/AES@PHEAA.Wilbert Pless
111/AES@PHEAA, Diane Freundel/PHEAA@pheaa. Brenda Gossard/PHEAA@pheaa. Jody
Teter/PHEAA@pheaa.Brittany L Wagner/AES@PHEAA
llalce: 12/20/'°-1.!L0~M
~JlJJect: Re: llb.li]J ID2.lifiljdenied ECF- AILA not qualify
Mikell, Because this is a complaint regarding our determination whether this borrower's employer is a public
service organization, we should not refer her back to her current loan servicer. For the same reason, we
won't be able to say it's simply a policy issue -- even though her concern does ultimately center on the regs --
at least not until we've explained the regulations which apply in greater detail than we already have.
As for those details, allow me to defer this to Kim, at least initiallv. I exoect either she or Diane will have had
(b)(5)
Copying PSLFSupes for visibility. Please see attachments below.
Thank you!
Matt Eshelman
PO Box 1845
717-720-2431
meshelma@pheaa.org
Fedloan Borrower Advocate---12/20/20"16 01 :53:33 PM---Good afternoon Matt, I have something of

an odd situation here. This borrower submitted a CFPB compl
I 1011, Fedloan Borrower Advocate/FedLoanServicing

lo· Matthew J Eshelman/AES@PHEAA
Wilbert Pless I11/AES@PHEAA.Jessica M Nieves/AES@PHEAA

rJ:,I- 12/20/2016 01 :53 PM
~ l,1cct Fw: [external]Re: TO: IZtiifill
~RE.You Student Loan Account with FedLoan
Servicing (Policy Issue - No Loans with FLS)
~. 111il)· Mikell L Czermendy
Good afternoon Matt,
I have something of an odd situation here. This borrower submitted a CFPBcomplaint against us,
however their loans are not actually with us, they're with Nelnet. The borrower was responded to
advising of this, and providing Nelnet's contact information, however, she followed up with separately
with the email I have copied below.
As this is a policy issue regarding the qualifications for what employers are considered eligible for the
borrower to participate in the PSLFprogram, and because we do not have an account, nor service and
loans, tor this borrower, how would you suggest we proceed with her request? Is this something you
can forward to FSA for us through channels familiar to you? And if we aren't going to do that, and
need to direct the borrower elsewhere, what should we tell her? Any guidance you can provide would
be greatly appreciated. Thank you.
----- Forwarded by Mikell L Czem1endy/AES on 12/20/2016 01 :48 PM -
I 1u11 IZtiifill
libl76ldlynch111@gmail.com>
.:., Fedloan 'sorrower Advocate <FedLoanBorrowerAdvocate@myfedloan.org>
llc!lce: 11/23/201609:41 AM...._
~- l•Jfl t: [external]Re: TO: llb.lJ]J ~ RE: You Student Loan Account with FedLoan Servicing
I Ii Mikdl-
I also wanted to follow up with about your following statement:
"It is afw imporrant to note that. 11sII sen'icer 1!(/('demf student lom1v mvigwd h:,:the !JS.
Department of"Educatimz. ire do not hare the a11thority to determine the 11ecessan·
q11alificatio11s
for an employer to he considered elit;ihle in ret;ard to the Puhlic Service J,om1
Fm:i;irenes.1·(PLSF) program. Federal Government regulation stip11!ates 1rhich emplo_rers.
I would like to formally request that my complaint is forwarded to entity with the
authority to determine whether an employer is considered eligible in regard to the Public
Service Loan Forgiveness (PSLF) program.
Please let me know if you have any follow up questions.
Best regards,
liliilll
0ill6DRfil@J
On Tue. Nov 8. 2016 at 9:42 AM. FedLoan Borrower Advocate

<PcdLoan8orrowcrAdvocalc mvfcdloan.oro> wrote:
Good afternoon Ms. (b)(6J
My name is Mikell. I am a Borrower Experience Advocate with Fedloan Servicing and
your case has been assigned to me. We are in receipt of your complaint through the
Consumer Financial Protection Bureau (CFPB) and have reviewed your concern.
However we have unfortunately been unable to locate an account for you in our system
using the demographic information you provided through the CFPB.
Can you please provide us with your Fedloan Servicing account number? You can find
your account number on any billing or account statements we send to you. If you are
unable to locate your account number, you may provide us with your full Social Security
number instead.
You may provide us this information by simply replying to this email, or by reaching out
to me using the contact information provided in my signature below.
It is also important to note that, as a servicer of federal student loans assigned by the
U.S. Department of Education, we do not have the authority to determine the
necessary qualifications for an employer to be considered eligible in regard to the Public
Service Loan Forgiveness (PLSF) program. Federal Government regulation stipulates
which employers
We appreciate your concerns and look forward to assisting you. Thank you, and have a
great rest of your day.
Regards,
Mikell Czermendy
PO Box 1845
FedLoanBorrowerAdvocate@MyFedLoan.org
Thi~ mes~age contain~ privileged and confidential information intended for the above addre~see~
only. If you receive this me~sage in error please delete or de~troy this me~sage and/or
attachments.
The sender of this me~sagc will fully cooperate in the civil and criminal prosecution of any
Code:PHEAA

To; ,Jason
Swartley
Cc: cdetar@pheaaorg: RobertG Cameron
Subject: Re: This will become our problem
Date: 03/29/2017 03:53 PM
JLS:
b)(5)

AES/PHEAA Legal & Compliance Services
1200 N. 7th Street
telephone# (717) 720-1568
fax # (717) 720-3911
JasonSwartley---03/29/2017
03:32:11PM---Please
call DanWeigle. Hejust called
me aboutit. I alsoseparatelysent it to him and inquired
From Jason Swartley/PHEAA
To· jjarecki@pheaa.org
Cc: cdetar@pheaa.org, Robert G Cameron/AES@PHEAA
D:1te 03/29/2017 03:32 PM
SJbject· Re: This will become our problem
Please call Dan Weigle. He just called me about it. I also separately sent it to him
and inquired about his knowledge. JLS
Jason L. Swartley
Chief Legal and Compliance Officer
PHEAA
1200 N. 7th Street
Phone (717) 720-3610
E-Mail: jswartle@PHEAA.org
JamesJ Jarecki---03/29/2017
02:53:52PM---JLS:I neverhad anycommunications
on this with anyoneinternalor at DOE. My pointof contactfor
From· James J Jarecki/AES

To: Jason Swartley/PHEAA@pheaa
Cc: cdetar@pheaa.org, Robert G Cameron/AES@PHEAA
Date 03/29/2017 02:53 PM
S"ibJcct: Re: This will become our problem
JLS:
b)(5)

AES/PHEAA Legal & Compliance Services
1200 N. 7th Street
telephone# (717) 720-1568
fax # (717) 720-3911
JasonSwartley---03/29/2017
02:28:12PM---1don't recallhearingaboutthis
before. It appears the "D" in "D4A" is broken. I am not sure if
Frorn Jason Swartley/PHEAA
To Robert G Cameron/AES@PHEAA,jjarecki@pheaa.org,
cdetar@pheaa.org
D:1te 03/29/2017 02:29 PM
S,Jbject This will become our problem
b)(5)
Education Law
In answer to ABA lawsuit, Education

Department says it never changed
loan forgiveness rules
Posted Mar 28, 2017 06:50 am CDT
By Lorelei Laird
Tweet
In response to a lawsuit from the American Bar Association. the U.S.

Department of Education appears to be arguing that it has never issued any
approval to participate in its Public Service Loan Forgiveness program.
The ABA sued (PDF) the DOE on Dec. 20, after the PSLF program began
disqualifying ABA employees and other public interest lawyers who had
previously been approved for participation in the program.
But in its answer (PDF) filed March 23, the DOE appears to argue that it did
not change the terms of the PSLF program, because approvals issued by its loan
servicer were tentative. Therefore, it says, there were never any approvals.
The PSLF program, authorized by federal law in 2007, permits certain people
who work in nonprofit and public service jobs to have their student loans
forgiven. Participants must work at a 50l(c)(3) nonprofit or provide certain
services to qualify, including ''public education." After 10 years in those jobs
and 120 on-time payments on their student loans. participants can have the
balance of their loans forgiven. The first loan forgiveness could be as early as
October of this year.
Participants submit an Employment Certification Fonn, pennitting borrowers

to confirm that they qualify for the program. Public interest employees have
started receiving denials of ECFs. the ABA · s lawsuit says. even when they
previously had been accepted. As a result, the ABA has lost employees and
prospective employees concerned about their ability to pay off high student
loan debt without the program.
Name plaintiff Geoffrey Burkha11, who at the relevant time worked for the
ABA's Standing Committee on Legal Aid and Indigent Defendants, alleged in
the lawsuit that he'd received confirmation in 2014 that his ECF was accepted.
Before taking the job, in fact, he confirmed eligibility with both the ABA and
the loan servicer, FedLoan Servicing. FedLoan Servicing later sent him a letter
accepting his ECF, which was attached to the lawsuit as an exhibit.
But more than two years later, the complaint says, FedLoan Servicing sent
Burkhart a letter saying the ABA "do[es] not provide a qualifying service,'' and
therefore his participation in the PSLF program was revoked after "further
research and after consulting with the department." That means Burkharfs 2.5
years of loan payments will not count toward loan forgiveness, despite the
initial assurances of FedLoan Servicing.
The Depaitment of Education's answer denies that Burkhart' s ECF had ever
been approved, or that its letter revoking his participation was a reversal.
Another named plaintiff in the case is an asylum officer for the federal
government who formerly worked for the ABA South Texas Pro Bono Asylum
Representation Project, representing unaccompanied minors seeking asylum in
the United States. Other name plaintiffs in the case work for the American
Immigration Lawyers Association and Vietnam Veterans of America. In some
cases, the lawsuit says, the plaintiffs actually have more debt then they did
when they graduated, because they made minimal payments under the
impression that they were working toward loan forgiveness.
In a message to ABA staff Monday, ABA Executive Director Jack Rives said
the DOE is suggesting that FedLoan Servicing's decisions are meaningless, and
that participants in the PSLF program therefore must make payments 10 years
before finding out whether the DOE will accept their applications. That denies
them information they need to make impmtant employment and financial
decisions.
"It's clear that the Depa1tment of Education changed the rules in midstream,''
Rives wrote. ''That action forces public service employees to gamble with their
financial futures and run the risk of being saddled with crushing, interest-
enhanced debt."
The case is a high priority for the ABA, Rives said.
The ABA Journal has reached out to the Department of Education for
comment. but had not received a response by time of publication.

Jason L. Swartley
PHEAA
1200 N. 7th Street
Phone (717) 720-3610
From: RobertG Cameron

To; ,JasonSwartley
Cc: cdetar@pheaa org: iiarecki@pheaa.org
Subject: Re: This will become our problem
Date: 03/29/2017 03:08 PM
(b)(5)
Robert G. Cameron
Deputy Chief Counsel and Vice President of Enterprise Compliance
PHEAA
1200 North Seventh Street
Harrbhurg, PA 17102-1444
Phone: 717.720.1555
Fax: 717.720.3933
Email: rcameron@pheaa.org
Jason Swartley---03/29/2017 02:29:12 PM---I don't recall hearing about this

before. It appearsthe "D" in "D4A"is broken. I am not sure if
From· Jason Swartley/PHEAA
To Robert G Cameron/AES@PHEAA, jjarecki@pheaa.org,
cdetar@pheaa.org
[)ate· 03/29/2017 02:29 PM
S"ibJcct: This will become our problem
(b)(5)
Education Law

Department says it never changed
loan forgiveness rules
By Lorelei Laird
Tweet
In response to a lawsuit from the American Bar Association, the U.S.

Department of Education appears to be arguing that it has never issued any
approval to participate in its Public Service Loan Forgiveness program.
The ABA sued (PDF) the DOE on Dec. 20, after the PSLF program began
disqualifying ABA employees and other public interest lawyers who had
previously been approved for participation in the program.
But in its answer (PDF) filed March 23, the DOE appears to argue that it did
not change the terms of the PSLF program, because approvals issued by its loan
servicer were tentative. Therefore, it says. there were never any approvals.
The PSLF program. authorized by federal law in 2007, permits certain people
who work in nonprofit and public service jobs to have their student loans
forgiven. Participants must work at a 50l(c)(3) nonprofit or provide certain
services to qualify, including "public education." After 10 years in those jobs
and 120 on-time payments on their student loans, patticipants can have the
balance of their loans forgiven. The first loan forgiveness could be as early as
Participants submit an Employment Certification Form, permitting borrowers

to confirm that they qualify for the program. Public interest employees have
sta11edreceiving denials of ECFs, the ABA' s lawsuit says, even when they
previously had been accepted. As a result, the ABA has lost employees and
prospective employees concerned about their ability to pay off high student
loan debt without the program.
Name plaintiff Geoffrey Burkhart. who at the relevant time worked for the
ABA ·s Standing Committee on Legal Aid and Indigent Defendants, alleged in
the lawsuit that he'd received confirmation in 2014 that his ECF was accepted.
Before taking the job, in fact, he confirmed eligibility with both the ABA and
the loan servicer, FedLoan Servicing. FedLoan Servicing later sent him a letter
accepting his ECF, which was attached to the lawsuit as an exhibit.
But more than two years later, the complaint says. FedLoan Servicing sent
Burkhart a letter saying the ABA ''do[esl not provide a qualifying service," and
therefore his participation in the PSLF program was revoked after "further
research and after consulting with the department.'' That means Burkhart's 2.5
years of loan payments will not count toward loan forgiveness, despite the
initial assurances of FedLoan Servicing.
The Department of Education ·s answer denies that Burkhart' s ECF had ever
been approved, or that its letter revoking his participation was a reversal.
Another named plaintiff in the case is an asylum officer for the federal
government who fonnerly worked for the ABA South Texas Pro Bono Asylum
Representation Project, representing unaccompanied minors seeking asylum in
the United States. Other name plaintiffs in the case work for the American
Immigration Lawyers Association and Vietnam Veterans of America. In some
cases. the lawsuit says, the plaintiffs actually have more debt then they did
when they graduated, because they made minimal payments under the
In a message to ABA staff Monday. ABA Executive Director Jack Rives said
the DOE is suggesting that FedLoan Servicing's decisions are meaningless. and
that participants in the PSLF program therefore must make payments 10 years
before finding out whether the DOE will accept their applications. That denies
them information they need to make impmtant employment and financial
decisions.
"It's clear that the Depa1tment of Education changed the rules in midstream,''
Rives wrote. ''That action forces public service employees to gamble with their
financial futures and run the risk of being saddled with crushing. interest-
enhanced debt."
The ABA Journal has reached out to the Department of Education for
comment, but had not received a response by time of publication.
Jason L. Swartley
PHEAA
1200 N. 7th Street
Phone (717) 720-3610
From: Jason Swartley

To; Daniel Weigle
Subject: This will likely become our problem
Date: 03/29/2017 02:32 PM
(b)(5)
Education Law

Department says it never changed loan
forgiveness rules
By Lorelei Laird
Tweet
In response to a lawsuit from the American Bar Association, the U.S. Depaitment of
Education appears to be arguing that it has never issued any approval to participate in its
Public Service Loan Forgiveness program.
The ABA sued (PDF) the DOE on Dec. 20, after the PSLF program began disqualifying ABA
employees and other public interest lawyers who had previously been approved for
participation in the program.
But in its answer (PDF) filed March 23, the DOE appears to argue that it did not change the
terms of the PSLF program, because approvals issued by its loan servicer were tentative.
Therefore, it says. there were never any approvals.
The PSLF program. authorized by federal law in 2007, permits certain people who work in
nonprofit and public service jobs to have their student loans forgiven. Participants must work
at a 50l(c)(3) nonprofit or provide certain services to qualify, including "public education.''
After 10 years in those jobs and 120 on-time payments on their student loans, pa11icipants can
have the balance of their loans forgiven. The first loan forgiveness could be as early as
Participants submit an Employment Certification Form, permitting borrowers to confirm that

they qualify for the program. Public interest employees have started receiving denials of
ECFs, the ABA's lawsuit says, even when they previously had been accepted. As a result, the
ABA has lost employees and prospective employees concerned about their ability to pay off
high student loan debt without the program.
Name plaintiff Geoffrey Burkhart. who at the relevant time worked for the ABA' s Standing
Committee on Legal Aid and Indigent Defendants, alleged in the lawsuit that he'd received
confirmation in 2014 that his ECF was accepted. Before taking the job, in fact. he confirmed
eligibility with both the ABA and the loan servicer, FedLoan Servicing. FedLoan Servicing
later sent him a letter accepting his ECF, which was attached to the lawsuit as an exhibit.
But more than two years later, the complaint says, FedLoan Servicing sent Burkhait a letter
saying the ABA "do[es] not provide a qualifying service,'' and therefore his participation in
the PSLF program was revoked after "further research and after consulting with the
department." That means Burkhart·s 2.5 years of loan payments will not count toward loan
forgiveness. despite the initial assurances of FedLoan Servicing.
The Depaitment of Education's answer denies that Burkhart's ECF had ever been approved, or
that its letter revoking his participation was a reversal.
Another named plaintiff in the case is an asylum officer for the federal government who
formerly worked for the ABA South Texas Pro Bono Asylum Representation Project,
representing unaccompanied minors seeking asylum in the United States. Other name
plaintiffs in the case work for the American Immigration Lawyers Association and Vietnam
Veterans of America. In some cases, the lawsuit says, the plaintiffs actually have more debt
then they did when they graduated, because they made minimal payments under the
In a message to ABA staff Monday, ABA Executive Director Jack Rives said the DOE is
suggesting that FedLoan Servicing's decisions are meaningless. and that participants in the
PSLF program therefore must make payments 10 years before finding out whether the DOE
will accept their applications. That denies them information they need to make important
employment and financial decisions.
"It's clear that the Depa1tment of Education changed the rules in midstream,'' Rives wrote.
"That action forces public service employees to gamble with their financial futures and run the
risk of being saddled with crushing, interest-enhanced debt.''
The ABA Journal has reached out to the Department of Education for comment, but had not
received a response by time of publication.
Jason L. Swartley
PHEAA
1200 N. 7th Street
Phone (717) 720-3610
From: FedLoan PSLF

To; FeJLppn
P§LF
Cc: fbl/51
Subject: Public: Re: American lmm1grat1on Lawyers Assoc1at1on
Date: 05/07/201412:12 PM
Attachments: American lmm1oration Lawvers Assoc1at1on.z10
AILA - Mission & Goals.odf
Hi Ian, Thanks again for talking with Kim and me today. The discussion really
helped!
We looked at the Mission and Goals of the AILA and we don't think this employer
qualifies. They definitely don't qualify under the public service they listed (public
education). Upon further review, we also couldn't find any indication that the
employees of the Association provide qualifying public interest law services.
Diane
FedLoan PSLF---05/06/2014 10:01 :18 AM---Hi Ian, Could you please review this
one. We were going to deny - it's a 501 (c)(6). They indicat
From Fedloan PSLF/PHEAA

To· publicservice@ed.gov
Date: 05/06/201410:01 AM
S.JbJect Public:American Immigration LawyersAssociation
Sent by· Diane Freundel
b)(5)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfreunde@pheaa.org
(Page 2 of 8)
OBTAINED BY STUDENT BORROWER o. I~

, . J l"I IPROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
,,,11 2
AMERICAN
.IMMll~MrION
LAWYERS
ASSOCIATIO:sl
M>rch19, 2014

FedLoan Servicing
P.O. Box 69184
RE:Public ServiceLoanForgivenessProgram
Dear Sir or Madam:
The American Immigration Lawyers Association (AILA)submit.,;;thi,;; l@.th~rto supplement its

request for certification as a qual1fy1ng"public servic@.organi7:ttion" tor purposes of the Public
program. AIIA i,; ~ priv;;ite,nonpartisan, 501(c)(6) not-for-profit
Service Loan Forgiveness {1-'.Sll·)
"public service organization" s@tforth in 34 CFR§685.219(b)..1
Founded in 1946, the American Immigration Lawyers Association (AILA)is the n;itional
association of immign1tion lawyers r!stablis:hedto promote justite, ddVlit.itc for fair und
reasonable immigration law and policy, advance the quality of immigr;,;ationand nationality law
and practice, and enhance the professional development of its members, As part of its
1 Untler 34 CFR 685.219(b), ;l. public serviceorganization me,1n~:

(1) A Federal,State, local. or Ttibal government organization,agency,or entity;
[2) A puhlic childor family serViceagency:
(3) A non-profit organizationunder srction .'i01(r.){~) cift'h,>Internal Revenul'Codethat is e,i:empt
from taxation Lir)tle1~i:diuu 501(a) ufLhe Internal Revenue Code;
(4) A Tribal collegeor university;or
(5) A privrite organization th.:it-
(i) Provides the f,;,llowing public services: Emergencymanagement,militaryservice,public
safety,law enforcement,publicinterest law services,early childhoodeducation(inducting
licensedor regulatedchild c:;i.re,Head Start and Statefunded pre-k[ndergarten),public
service for individualswith disabilities,and the elderly,publit.:he<1lth(includingnurses,
nurse practitioners, nurses in a clinicalsetting,.ind full-timeprofessionalsengagedin he:alth
i.:ar~pn:11.;Utioner
occupationsand health care ~upportoccupations,as such terms .ire detinect
of Labor Statistics), public cdu<:ation,public library services, school library or
by the Burt;?(I.U
other school-basedservices;an<l
(ii] ls rult a business organlzedfor profit, a labor union, a parti$Cm political
organization, or an organfaation engaged in religious t1~tlvitie$,unless the qualifying
actiVitiesare unrel:ated to religiousinstruction,worship services. or any formllf
proselyti;:ing.
(emphasisaclded)..
AILA NatlonalOffice
1331GStreet
NW. Suite300,Wrishing!on.
DC20005
IOI 5077600I Fax:202.783.7853
Phone- I l\'WW.,:ii/i).Ofg
(Page 3 of 8)

,,,11 3
advocacy mission,AllAeducates the public about the ways in which fair and reasonable U.S.
immigration laws and policyserve the national interest by reuniting Americanfamilies, injecting
much-needed investment dollars into the U.S.econrimy ~nd creating jobs, protecting refugees1
and providing U.S.employers with the flexibilitythey need to remain globallycompstitive.
Through ils 11dlium1I
office and chapters, AILA also promot@sand supports the dP.livl'lry
ot
compet~nl, ethical, andlawfulpro bonoimmigration SE':(\fiCes to the general publlc.
Under 34 CFR§685.219(b), AILA qualifies as a "public service Nganization" because it is a

private, nonpartisan, 501(c)(6)not-for-profit org;;inizationthat provides publrceducation
• AILA'~W~bsltt-:AILAprovides its members and the public with up-to-date information

on immigration law and policyprimarilythrough its website, available at www.ail.;1_org.
frequently posts resources such as Immigration Politics2014 (AllADoc. No.12120666),
summaries of proposed/enacted immigration legislation (AILADoc.No. 13041944),
analysis of administrative policychanges {AILA Doc. No. 12032760),pertinent
immigration news articles, legislativealerts and updates (AILADoc. No. 13,020647),
current legislation (AILADoc.No.14012141), con~re:i:iiom1I votes, congressional
communications (AILA Doc. No.14013053), AILA lelters to r,;overnmentofficialson
select policy issues{AILADoc.No. 14022643),amicusbriefs (AILADoc, No..14021243),
and more. 2
AlLA'swebsite reaches a broad segment of the public that is interested in U.S.

issues. Individualswho visit our website indud@immigrdtionattorn~ys in
i111rnii-:rntio11
private practice, nonprofit immigration attorneys, govflrnment attorneys, media
representatives, U.Sbusinesses, foreign nationals, members of Congress and their staff1
• Collaboration with S01(c}(3}and Other Not-For-Profit Organizations: AILAworks

closelywith other 501(c)(3) and other not-for-profit organizations, in particular, its sister
501(c)(3)orgJniz~tion, the American lmmigr:itio11 Council,to provide aci;:urnte
inform:ition on immigration law and procedures to the public.3 In addition, AILA
backgrounders, and regulatory comments on new or evolvingimmigration law
developments 1 and briefs of amlcus curiae to assist courts in rendering impact decisions
on immigration law that are fair, reasonable, and consistent with the law. AILAis also a
partner ofth@ ImmigrationAdvocates Network (IAN), a collaborative effort of leading
z These resources can be accessf'd hy vi.~iring www.aila.org and typing the AlLA document number in the
search box in the top right comer.
3
The Amertcan lmniigration Council (AIC),formerly the American Immigration Law Foundation (AJLF),has a
mission to strengthenAmerica by honoring our immigrant history and shaping how Americans think and act
towards immigration now and in the future. AIC provides support ta AILA's advocacy effort&-though its
research ahd rnatcrlals, as well as it practice advi.sorics and litlgation throughthe Legal Action Center.
(Page 4 of 8)

IPROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
,,,11
, . J l"I 4
immigrants' rights organi;;ations designed to increase access to justice for low-income

immigrants and strengthen the capacity of the organi2.ations serving them. IAN
immigration advocates ~nd organizations by providing free, easily accessible, and
comprehensive on line I t:.'lourc~s and tools.
• Media Cornmentary: AILA staff, AILA leadership, and AILA members are contacted
the field.
• Legal Education Opf)ortunities: AILA offers numcrou:., lcgul education opportunities and
in-person conferencfls 1 live webcasts, live audio and Wi:'b seminars, and OnDemand
Immigration lawyer, which includes books and resources used by law school
1
government agencies1 nonprofit organ'1zations, and attorneys in private practice.
• Pro Dono Programs: AllA provides the public with pro bono service programs such ns
provides free or low-cost assistance to eligiblfl legal permanent rflsidents who wi.~h to
apply for U.S. citizenship 1 utilizing partnerships between AILA chapters across the
country and grassroots organizations, AILA Military Assistance Program (MAP) is a
collaborative effort betwsen AILA nnd th@ I @galAssistance Offices (LAO) of the United
States military Judge Advocate GenP.ral',i;(JAG) Corps that provides knowledgeable pro
bono legal counsel to men and womi:'n of the United States Armed Forces.
AILA is a private organi2ation that prrivides the above public services; it is not a business
publri;: service organization for purposes of PSLF.If you have any questions, please feel free to
contact mP directly at 202 507.7650 or via e-mail at tw<"1tcrs@aik1.org ..
Sincerely,
Theresa A. Waters
/\mcric;;in Immigration Lawyers Association
(Page 6 of 8)
9: I4AI/ 6
b)(6)
9orrower Nam Borrow...-.SSNr)(B)
SECTION3:
I
SGBSBction3 ot 1h11
accomp~"Yi•1g Ctrliii~o/ion fw Pubfro
/mtruc/ion3forComp/11/inqErnp/Qyr11t:;(// An authom~ officlsl (.....,Section~) ,:,fthe publicGllrvice
StrviceLoanForgivanassfcrdetsied1n101mabOl'I on wmplet1ngthii fsabon. O~niza(ion a( which the lxim>werlsM',u=ployed mu5i
TheaelrutructlMSare alw IQi;a\ijdat www.slu ed.novinubli□servioo
completelhOl:sK!ion.
ln&tnmtiono for Authc,MredOfficial;

. Complete1n1,!¢rm9nly ify-,u ~~ 1111
~ulhllriiledllfflwl Qf the publiG6erviooorganirntioam 1111hlMtile oorrowerielenliliedin Stt~on 1 is/w!tg employ@.l
or It (~e
. borromir 1ofwa:1
a ru11,11me
Readthe de~nit1ons
AmeriCorvsor PeaceCorpB\/Olunteer~n authOriz.ed
in Sec11Dn
5 tr.,loreCOit'lllleting
thisform.
offici.i!of AmeriCorpsorth,1,P,1,~c,1,
CO'll~-
.. Typ~or prl~t~:lir'i!I ink. All ~dd~ rr,~~Iii<:wrnpl~lc:Uif <i~J)ii(;t[bil!.

~Im;<>rblac:11 Yu111
i:.i11n~tu1~
l'twi\le all requestedinformationlor Ileitis 1. 2, and 3 below. CompletBtlie em~l<,>Y,:~$
cannotbe pro,:es~edif 1heinfoITTlll1ionra<JUested In thi~seetionis missing
dolt: rnuMi111:lude
es,rtilie.i.li~n
monlll, day, and year (~M-DD-l'YYYJ,
~t th"' bottomof this page The EmploymenlCertificali11n
form
. 11you make ~ny ch~"lles m the lmmm~\tonyou pr<:>\/ide

in th~ section,you mu~r1n1var
e~~he~ar'i!le.
Pleaeereturn the eom11l~tlldform to th!!-borrownr_ 'r'M U.S. OepMmenlof Educationortlte P.'lLF,ervlce, o'\\llVeo~l~etyou Foradditic>nal informationor
doeui11er11at;on
. forlklrfllwerwhen tllel'{I ii'; no Authorized Offlclal'.

!1'1$trY~tiorn;
0 Checkthis box iFyouare unableto obtaino,:,rt1fie.\l10n
inforrna!lonfor Items 1, 2, and 3 below For 11
from an authonzedoff,clal,for e"-'lmple,beeau$10'\heoro;,anizalion no longerexi,ts. ~rooldeall re~ueslc,d
..m 1, Ii~ the or,iarnzation·•addraeBfrom when you worlw(l (lie~. and ron5Liltyour W2.mcordafor t~e EIN,T~e
Deoartmen1w111 vo~t(oWbm1(~ddi1i1mal
reoulr'le eviden~ or youl._9.~alii.D.l!_
tl!)J IQ.t_ment Do n □ t ;ubmil ;uooanln □ OOCLitller'\S
uOli teou~~t@.dto do so.
1. Information about the puhlit: urvit:11 nr911nin1tion1!.twhlth !ht. b0r"16w.:.1 itlw~~ <>mplo~il-
Amerl,:-;in Tmmicrr,.t.inn
Public Service OrganizationName
I ""~Ill""~ ~:!S!:ociaation
12131· 11101~161o1q1~1
FedNally Ass1gMd Employer 10# (EIN)
J.3:31.G. Street HW, S:1Jite- 300, ""~hington DC 2 □ 005
Public Service Organiz..tionAd(lress
2. Borrower's Employment Slalu.__

(b)(6)
{•) D;ites of employment. S(art
(MM-DD-YYYY)
{bl Borrower's Bm!lh',vr'nantstatus at vo1irorgJ1.nira:1Uon•
IX]Full-Tlme Averagi;,numbi;,rof ~ou~ p,:,rwetk. ~

0Part•Tlmit Avsra!J" number of hours per week: ___
For purpose$of eliQibllllylot PSLF. full-time employment isde!in&d as.

(1) Working in qualifying employment in one or more jobs tor the gre~er ot:
(A) An annual average orat llalc16t a
~o hou~ per week or. for a contractual or employment perio,:tot at least months, a.-.avareg~ of 30 hour,: per
week: or
(BJ Unle~ the qualifying amploymBntig with two or more employ,ns, the num~er of h□ur;i lhe employer oons1der$full-lime.
(2) Vsi<;-\1\IOn oy tne employer or ltlclvetaken for <l condition thal is a qualiMnq r1monfor leave under the Family and Medical
or lrt.iva ume prov10e1:1
Lea\'ti Act of 1993, W U.S.C. 2612(a)(1)aml (31is eouivalelll 10hours IM'H'lfficl in Qual1fy1ng employment.
NOTE: A lull-lim~ Amari<-nrpaor Peace Corps volunlMr i~ conBid,;,r,;,~ si fo,11-time
emp!Q~e for oligibili!y purp11,_,,fQrP-SLF
3 Typl! of Public Servk<>Or!Jilniz.!lti<.>n,

In aeeordance with the definition In Sec lion~ (Chl'ltk onn),
(a) D
A9ovornmtmt oreani2ation (mclud1nga Federal. Slat~\ local or Tribel organizi;ition.agency orenlity' a J)Ubllcchili'.l""°fumily 5erv1oeagency-or
a Tribal college or university)'
/bl 0 A non-profi!, WK-e~empt otganization u.-.der Section 501(Q)(3)Qfthe lnWmal fi.nenue Code:
le) Jg) A 11rivate.n11n-prolitorganliation (lh~l ls not a labar union or a partis1mpolitical organization) Iha\ pro~ides at lee.i.toni; of 1hefollowin1,1
publie
sar,icea (check all that apply)·
0 Erlltll'!ltlncy IJl<lnsigement
□ Mili!ery service.
0 ~1,hlir,~MAiy,
D Lawenlorcemenl.
D Public interest law ~~rvices.
D Esirlychildhood edi,cation (including licensedOf regula\td ctilld tare, Hesd Simi, arn;ISt:,te-l\J11dedpre-kindergarten).
0 Public StrviC8 !0rmdivtdual5 wilh d1s11b11111eg and 1hll etdar1y,
D Public haaljh Onclui:lingnufSeS.nu~ praciilioners. nurses in a clinical settln{l. anr:1full-Iima prnfeesi<.>nals eng<"gedIn ha~llh o':.;!IM
Pl<lctitioneroccupalion6 end health suppon oceupatlons. as~- 1ennsare Oe~nedby t~e Bureau of Labor Sia:ilistica),
lo) Publ1tOlldwoat,on,
□ Public l1t,ra,yservices,
□ School 1lb1ary~ervicea,or
0 Other Gchm;,1-ba~ed services.
NOT!::<1sto ca1egonea[bJ and (CJ:~or purpo~e~of Iha full-11merequirement(Section 3. Hem2.(bl above). .aborrower's Qli3lllylnl) tn'l'lpl □ yment does not
include l1m0spi;nt on job du~es lhal ere related 10reli{liouSinstruction, 11\'0rship seiv1ces,or any form nt pros1dyli?ing
I certity lh~l lhe borrower ioen!if1edIn SQCtiOn1 ebove i~lwas employed tit a publk: service □rgeni~<"lion, .:ISindicated abov.!:.or ls/w~~ sef\ling 1nan
AmeriCorp;. or Peace Corp~position (m si~cordancewllh the definitionEof lhe3e terms in Section 5) during tl'Kl p13riodiden1ilie,;iin l(e.111 2(a) of this seclion.
Theresa A. Wat.!r$ Sanlor OiMCIOr,HR 1mdAdminislralion
A~tjed Otliclal'£ ~me (Printed) A~tll□ 1ized Oflle1~1·~
Tille
. WQ le\ \202 I 507-7600 03' 19· 201~
Authorized Offic1iil'~Sinnatur~ Aulhori.:ed Offi~1al'~Televhone T□d;iv·s O;i(,;, MM-DD-WYV
""°"'I lioll> I ~ I ~ I ~ I Ml2l2lli> ~ -

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efile GRAPHIC rint - DO NOT PROCESS As Filed Data - DLN:93493189007273
0MB No 1545-0047
OBTAINED BY STUDENT BORROWERReturn
PROTECTION CENTER AND AMERICAN
of Organization ExemptFEDERATION OF TEACHERS
From Income Tax UNDER THE FREEDOM OF INFORMATION ACT
Under section 501(c), 527, or 4947(a)(t) of the lnlernal Revenue Code (except
benefil trust or private foundation)
black lung
2012
'l'l"I'" r·-.'i,, ·, "1 Open to Public
·1,•1".IP,,,c ► The organIzatIon may have to use a copy ofth,s return lo satisfy slate reporting requirements
Inspection
A for the 2012calendar ear or tax ear be innin 01-01-2012 2012 and endin 12-31-2012
C IJ,\l'r<' d urq,,iw,>111,n
B ("l"•,k ,r,lppl1<.,blv AML~lCNJ lMMJGRAI !OIi L~WYLK5 ,\550ClJ\l 10N
D Employer identification number
I Add1<·ss,I,,,.,q,· 23-7085097
I I11ItIalrelLJrn N11mbc1 ,-.nd --tr~N (N ,, () ho, If m,,rl I< n,,t d~,,,~r,•rl '" str~,•t ,1rl<11~,--1l(c,0m, SIJlt~
1111 r, STRfFT N\V IIO "JOO
(202)507-7600
( 11¥ IH n,wn, st<0t,• or 1111m11y, """' /IP
WASIIINldON, DL 2000',)14/
f riame and address of principal officer H(a) Js this a group return for
CRY ST AL WI LL! AMS aff·l1ates> I Yes F No
1331 G STREET Nl'HIO 300
WASHINGTON,DC 200053142
H(b) /\re all aff1l1ates ,ncluded>I Yes I No
Jf"No," attach a list (see ,nstruct1ons)
1,1' ,•,~mpt -.,,-,,,,, I IO!(c)(J) F OOl(c} (GI ◄ (rnert 110} I "94,"(a)(l) or I 121
H(c) Group exemption number ►
Website: ► WWW A I LA O PG
K Fo1111
uf <>nj<0111/,lllu11 F (0II>111,lt,0I,I T,u,1 I Awa,.,,,,,,, I Ot1,.,, ►
Summary
1 B11efiy describe tile organ,zat,on's m,ss,on or most sign1f1cant actIvItIes
NAT'L ASSOC OF LAVIYERS PROMOTING JUSTICE AND ADVOCATJNG FOR FAIR IMMIGRATION LAW& POLICY
2 Chec;k this box..,-- 1fthe organization d1scont1nued ,ts operations or disposed of more than 25" of,ts net assets
Numberofvot,ng members of the 9overn111g body (Part VI, line la) ,,

4
3
Number of Indepe11dent vot,ng members of the governing body (Part VI, line lb)
' ,,
5 Total numberaf1nd1v1duals employed ,n calendar year 2012 (ParlV, line 2a)
's es
6 Total r1umber of volur1teers (estimate ,f r,ecessaryj ,cc
7aTotal unrelated business revenue from Part VJ)! column (CJ, line 12 ,.' 102,600
b Net unrelated business taxable ,ncome from Form 990-T, line 34 ,7 5 0
"
-)
Prior Year Current Year

8 Contribut1011s and graots (Part VJJl, line lhl 0 0
, Program servI<:e rever1ue (Part VIII, line 2g) 5,862,682 s ,589,271
rn Investment income (Part VIII, column (A), lines 3, 4, and 7d) 82,281 ,62 2
H Other
Total
revenue
revenue-add
\Part VIII, column
l1res 8 through
(A), lines
11 (must
5, 6d, 8c, 9c, 10c, and 1 le)
equal Part VIII, column (Ai, line
, 194,874
•" ,161,306
" "I
" ,139,837
" "' ,S 2 5
13
14
Grants
Benefits
and sImIlar
paid to or for members
amounts paid (Part IX, column
(Part IX, column
(Al, lines
(A), line 4 /
1-3
'" ,000
0
''° ,673
0
15 Sa lanes, other compensation, emplovee benefits (Part IX, column (Ai, lines
5-10) 5 ,3 S 9 ,834 5,815,824
16a Professional fundra,s,og fees (Part [X,colun1r1 (A), line lle) C C
b lotal t,mdrais,nq ~xp~ns.es (Part lX, ,:cdumri (DL l,ne 21) ►-"-----------
Ottie, expenses (Part!X,coluInn (A), lines lla-lld, llf-24e) 5,692,572 6,348,391
" Total expenses Add lines 13-17 (must equal Part JX,column (A),I,ne 25) 11,344,406 12,580,888
" Revenue less expenses Subtract line 15 from l,ne 12 795,431 244,311
" Beginning of Current
End of Year
Year
Total assets (Part X, line 16) 29,620,491 30,227,847
Total I,abIlIt,es (Part X, I,ne 261 16,374,523 19,255,529
Net assets Mfund balances Subtract line 21 from line 20 11,245,968 10,972,318
Signature Block
Under penalties ofperiury, 1 declare that I have examined this rnturn, 1nclud1ng accompanying schedules and statements, and to the best of
my knowledge and belief, It 15 true, COl"rect, and complete Declaration of preparer (other than officer) 15 based on all 1nformat1on ofwh1ch
preparer has any knowledge
......
►
I ;,11 , r,1 ns
c,,qn,,ture ul c,llicer Oate
Sign
Here
►
SIJSMJ QIJ/,RIFS ~FPLJT'/ FXF '.UTfVf DlRFCTOR
I vp~ m pnnt n.-.r-1~,1nrl tltl,•
Pr11l1hp,' pr,•p,,,,-,·,
IRMJKIIC,1-11111
'"""" I Pt<'fhll,•1'•, ',l'llhltlJt,• ID,l11'
2013-(l/-0\
, 1,0 ,k I ,r
,,,11 ,•rn ,lov,•d I
I PTJN
POOJU\399
Paid t 11rn·, n,11nc ► lrnFIAl'C I 11n,'s lltJ ► ',/ l ',I I!,',
Preparer
Use Only
r ,,,,,·, ~,lchesc, ► i~99L~IKLLI rJw ~UJrl 'JflV """"e ,,,, (!O.i) ~U-'.>UUO
WA~IHN<ilOrJ, OC .i0031,
OBTAINEDMay
BY the
STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THEFYes
JR$ discuss this return with the preparer shown above> (see 1nstruct1ons)
FREEDOM
!No
OF INFORMATION ACT
for Paperwork Reduction Act Notice, see the separate instructions. Cill No 11282Y Form990(2012)
From: Diane Freundel on behalf of Fedloan PSLF

To; p11blicservice
Subject: American Immigration Lawyers Association
Date: Tuesday, May 06. 2014 10:01 :33 AM
Attachments: American Immigration Lawyers Assoc1aj1on.z1p
b)(5)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfreunde@pheaa.org
This message contains privileged and confidential information intended for the above addressees only. If you
receive this message in error please delete or destroy this message and/or a\lachments.
The sender of this message will fully cooperate in the ci vii and criminal pru~ecution of any individual engaging
in the unauthorized use ofthi~ message.
0MB No 1545-0047
black lung
2012
Inspection
I Add1<·ss,I,,,.,q,· 23-7085097
(202)507-7600
( 11¥ IH n,wn, st<0t,• or 1111m11y, """' /IP
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, 194,874
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(A), line 4 /
1-3
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''° ,673
0
5-10) 5 ,3 S 9 ,834 5,815,824
End of Year
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OBTAINEDMay
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(Page 6 of 8)
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doeu111en1at;on
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Amerl,:-;in Tmmicrr,.t.inn ~:!S!:ociaation

Public Service OrganizationNeme
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12131· 11101~161o1q1~1
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J.3:31.G. Street HW, S:1Jite- 300, ""~hington DC 2 □ 0 □ 5
2. Borrower's Employment Slalu.__
{•) D;ites of employment.

(MM-DD-YYYY)
S(srt l..£.J.._9JL"l.!.I I 2 I O I 1 I 3 I End· 10(31· @1 -1'-1°1\ 1'-1I
(II the borrower is slill employ~, pu1tod~y·s datt)
{bl Borrower's Bm!lh',vr'nantstatus at vo1irorgJ1.nira:1Uon•
IX]Full-Tlme Averags,numbs,rof ~ou~ p,:,rW@ek. ~

0Part•Tlmit Avsra!J" n1Jmberof hours per week: ___
For purpose$of eliQibllllylot PSLF. full-time employment isde!in!l-d as.

(A) An annual average orat llalc16t ~o hou~ per week or. for a contractual or employment perio,:tot at least a months,cli"Iavarege of 30 hour,: per
week: or
(BJ Unle~ the qualifying amploymBntig with two or more employ,ns. the num~er of h□ur;i lhe employer oons1der$full-lime.
(2) V~<;-\1\IOn oy tne employer or ltlclvetaksn for <l condition thal is a qualiMnq r1mon for leave under the Family and Medical
Lea\'ti Act of 1993, W U.S.C. 2612(a)(1)aml (31is eouivalelll 10hours IM'H'lfficl in Qual1fy1ng employment.
NOTE: A lull-lim~ Amari<-nrp~or Peace Corps volunlMr i~ conBid,;,r,;,~ ~ -fo,11-time
emp!Q~efor oligibili!y purp11,_,,fQrP-SLF
3 Typl! of Publle Servk<>Or!Jilniz.!lti<.>n,

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A9ovornmtmt organi2a(i<,1n(mclud1nga Federal. Slat~\ local or Tribal orgenizi;ition.agency orenlity' a J)Ubllcchili'.Iorfumily 5erv1oeagency-or
/bl 0 A non-profi!, WK-e~empt organization ui"lder Section 501(Q)(3)of the lnWmal fi.nenun Code:
(e) Jg) A 11rivate.non-profit

organliation (lh~l ls ~ot a labar union or a partis1mpolitical organization) Iha\ pro~ides at lee.i.toni; of 1hefollowin1,1
publie
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D E:,rly childhood edi,cation (including licensedOf regulated ctilld ca~, Hesd S!srt, arn;ISt:,te-l\J11dedpre-kindergarten).
0 Public serviC8lormdivtdual5 wilh d12ab1llllegand 1hll eldsrly,
0 Public haaljh Onclui:lingnufSeS.nu~ praciilioners. nurses in a clinical settln{l. anr:1full-Iima prnfeesi<.>nals eng<"gedIn ha~llh o':.;!IM
Pl<lctitioneroccupalion6 end health suppon occupations. as~- 1ennsare Oe~nedby t~e Bureau of Labor Sia:ilistica),
lo) Publ1tOlldwoat,nn,
□ Publ10l1t,ra,yservices,
0 Other schm;il-b(l~edservices.
NOT!::<1sto ca1egonea[bJ and (CJ:~or purpo~e~ofths full-11merequirement(Section 3. Hem2.(bl above). .aborrower's Qli3lllylnl) Bri'lplaymentdoes not
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.:ISindicated abov.!:.or ls/w~~ sef\ling 1n11n
AmeriCorp;. or Peace Corp~ position (m :,ccordance wllh the definitionEof lhe3e terms in Section 5) during tl"Kl p,3riorliden1ilie,;iin l(e111
2(a) of this seclion.
Theresa A. Wat.!r$ Senior OiMCIOr,HR and Arlminislralion
l(b)(6~ Autllo1ized Oflle1~1·~
Tille
'
I (202 I 507-7600 03' 19· 201~
Authorized Offic1iil'~Sinnatur~ Aulhori.:11dOffi~1al'~Televhone Tod;iv·s O;i(,;, MM-DD-WYV
(Page 2 of 8)

,,,11 2
AMERICAN
.IMMll~MrION
LAWYERS
ASSOCIATIO:sl
M>rch19, 2014

FedLoan Servicing
P.O. Box 69184
Dear Sir or Madam:


by the Burt;?(I.U
proselyti;:ing.
(emphasisaclded)..
AILA NatlonalOffice
1331GStreet
DC20005
IOI 5077600I Fax:202.783.7853
(Page 3 of 8)

,,,11 3
ot


and more. 2

i111rnii-:rntio11

3
(Page 4 of 8)

,,,11
, . J l"I 4
immigrants' rights organi;;ations designed to increase access to justice for low-income

immigrants and strengthen the capacity of the organi2.ations serving them. IAN
immigration advocates ~nd organizations by providing free, easily accessible, and
comprehensive on line I t:.'lourc~s and tools.
• Media Cornmentary: AILA staff, AILA leadership, and AILA members are contacted
the field.
• Legal Education Opf)ortunities: AILA offers numcrou:., lcgul education opportunities and
in-person conferencfls 1 live webcasts, live audio and Wi:'b seminars, and OnDemand
Immigration lawyer, which includes books and resources used by law school
1
government agencies1 nonprofit organ'1zations, and attorneys in private practice.
• Pro Dono Programs: AllA provides the public with pro bono service programs such ns
provides free or low-cost assistance to eligiblfl legal permanent rflsidents who wi.~h to
apply for U.S. citizenship 1 utilizing partnerships between AILA chapters across the
country and grassroots organizations, AILA Military Assistance Program (MAP) is a
collaborative effort betwsen AILA nnd th@ I @galAssistance Offices (LAO) of the United
States military Judge Advocate GenP.ral',i;(JAG) Corps that provides knowledgeable pro
bono legal counsel to men and womi:'n of the United States Armed Forces.
AILA is a private organi2ation that prrivides the above public services; it is not a business
publri;: service organization for purposes of PSLF.If you have any questions, please feel free to
Sincerely,
Theresa A. Waters
/\mcric;;in Immigration Lawyers Association
From: Baker Jeff

To; ~
Subject: Does this work??
Date: Wednesday, October 15, 2014 7:59:36 PM
Attachments: PSLF AILA 20140825 Foss-baker-October 15 docx
Page 4597 of 7666
Withheld pursuant to exemption
(bi(51
of the Freedom of Information and Privacy Act
Page 4598 of 7666
(bi(51
From: Mclarnon Gail

To; Moran Pamela; Ninemire Sandra;~
l.J..tL....J..Q;
Subject: Eligible employment/Public Service Loan Forgiveness Program
Date: Tuesday, June 19, 201210:50:04 AM
(b)(5)

Sent: Tuesday, June 19, 2012 9:17 AM
To: Mclarnon, Gail
Subject: FW: Public Service Loan Forgiveness Program
(b)(5)
.\!aurcv11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )ftlCL'()r i\()[l Publ!C l.duc:i.ti(ll1
( )fricv (Jf l1111cJY:tti(i11
;u1d ln1pnJ\Tt11c11t
l·.s. Dvpanrncnt ()f l·.ducat1CJ11
...J-!Hl
\hrybnd .\n·mic, S\\
\\-a\h111gtrn1, DC 2().2112
:'2112)2(11J -:-t-;21
I
maureen.do'\vlino·(t/:edy(1\·
Join the ONPE listserv!
From: ~ l(b)(6JIj(b)(6J ; ;
Sent: Friday, June 01, 201Z.z:.v;:, n,v,
Hi Ms. Dowling,
I wanted to follow up with you on our discussion about the Public Service Loan
Forgiveness Program. I am trying to find out whether my current position as a
Liaison and Information Associate would count as qualifying employment. I work for
the American Immigration Lawyers Association, which is a 501 (c)(6) organization. Do
you have any ideas where I could go to find an answer to my question? None of the
information that I've seen on the website or that I've gathered from talking with
customer service individuals seems conclusive. I've even looked through the statutes
and regulations, which seem to indicate it would qualify, but I'm not sure. I have
included below some background information on both AILA and my position, but
please feel free to let me know if you need more! Thanks so much for your help, and
I hope to see you soon!
!(b)(6) I
AILA: The American Immigration Lawyers Association (AILA) is the national
association of immigration lawyers established to promote justice, advocate for fair
and reasonable immigration law and policy, advance the quality of immigration and
nationality law and practice, and enhance the professional development of its
members. AILA has over 11,000 attorneys and law professors members who
practice and teach immigration law. AILA Member attorneys represent U.S. families
seeking permanent residence for close family members, as well as U.S. businesses
seeking talent from the global marketplace. AILA Members also represent foreign
students, entertainers, athletes, and asylum seekers, often on a pro bona basis.
Founded in 1946, AILA is a nonpartisan, not-for-profit organization that provides
continuing legal education, information, professional services, and expertise through
its 36 chapters and over 50 national committees.
Position Description: The Liaison and Information Department provides direction to

and coordination of agency liaison efforts, conducts substantive legal research and
analysis, and gathers and disseminates information to members and the public. The
Liaison and Information Department works with liaison committees, the executive
committee and the board of governors to set and achieve liaison goals, and works
with government agencies to achieve those goals in close coordination with other
internal functions, including Advocacy, Communications, and the LAC and IPC. The
department also coordinates AILA participation in coalition groups, responds to
member questions, coordinates information gathering and dissemination, and
develops and manages lnfoNet and other Internet-based dissemination
programs. The Liaison and Information Associate provides support to designated
AILA liaison committees, and coordinates assistance to AILA members with respect
to information needs. The Liaison and Information Associate maintains contact with
various agencies, monitors administrative developments, and seeks answers to
member questions/problems.
From: Mclarnon Gail

To; ~
Subject: FW: Eligible employment/Public Service Loan Forgiveness Program
Date: Monday, July 07, 2014 2:47:48 PM
I lcre is the email exchange regarding AILI\.

Sent: Tuesday, June 19, 2012 12:12 PM
To: Foss, Ian
Cc: Utz, Jon; Moran, Pamela; Ninemire, Sandra
Subject: RE: Eligible employment/Public Service Loan Forgiveness Program
Thar1ks, Ian
From: Foss, Ian

Sent: Tuesday, June 19, 2012 11 :06 AM
To: McLarnon, Gail
Subject: Re: Eligible employment/Public Service Loan Forgiveness Program
(b)(5)
On Jun 19, 2012, at 10:50, "McLarnon, Gail" <Gail.McLarnon@ed.gov> wrote:

(b)(5)

To: McLarnon, Gail
(b)(5)
.\iaurL'cn
.\iaurL'cn D()\\ ling, l .d. D.

DirL'Cl(lr
( )fficc cJf \:(Jn-Puhhc l ·.ducati(i11

( ) ffi cc c J f l rn H l\"'1 th Jll a ml I rnpn in·rn c1lt
l '.S. Dcp:1.rtrnu11 (>fl .duc:i.ti(m

·11111 .\Jan land .hu1uL', S\\
\\ :i.shington, DC 21121!2
1TUUnTndmylinl'IJ'"l,,cd
vm·
Jnin the ONPE listscrd
I
'cc~=--~~--~~
From: liliiill]l(b)(6J (b)(6J
Sent: Friday, June 01, 2012 12:05 AM
Hi Ms. Dowling,
which is a 501 (c)(6) organization. Do you have any ideas where I could
go to find an answer to my question? None of the information that I've
seen on the website or that I've gathered from talking with customer
service individuals seems conclusive. I've even looked through the
statutes and regulations, which seem to indicate it would qualify, but I'm
not sure. I have included below some background information on both
AILA and my position, but please feel free to let me know if you need
more! Thanks so much for your help, and I hope to see you soon!
!(b)(6) I
national association of immigration lawyers established to promote
justice, advocate for fair and reasonable immigration law and policy,
advance the quality of immigration and nationality law and practice, and
enhance the professional development of its members. AILA has over
11,000 attorneys and law professors members who practice and teach
immigration law. AILA Member attorneys represent U.S. families seeking
permanent residence for close family members, as well as U.S.
businesses seeking talent from the global marketplace. AILA Members
also represent foreign students, entertainers, athletes, and asylum
seekers, often on a pro bona basis. Founded in 1946, AILA is a
nonpartisan, not-for-profit organization that provides continuing legal
education, information, professional services, and expertise through its 36
chapters and over 50 national committees.

the boardof governorsto set and achieve liaisongoals, and workswith

coalitiongroups,respondsto member questions,coordinatesinformation
other Internet-baseddisseminationprograms.The Liaisonand
Information Associate provides support to designated AILA liaison
committees, and coordinates assistance to AILA members with respect to
informationneeds. The Liaisonand InformationAssociatemaintains
contactwith variousagencies,monitorsadministrativedevelopments,and
seeks answers to member questions/problems.
!{b)(6) !!(W6fl
(b)(6)
From: Foss Ian

To; FedLoan PSLF
Cc: 011blicservice:Chialastri Taneka: Battle Cynthia: ,Johnson Debbe
Date: Wednesday, December 10, 2014 3:37:00 PM
FYI
From: Foss, Ian

To: l1bl(61 ~ I
Cc: bowling, Maureen; Mc arnon, Gail; Moran, Pamela; Arnold, Nathan; Smith, Brian; Utz, Jon
Dear Ms. l(b)(6J I

Kind regards,
Ian Foss
Federal Student Aid

1 iJ 201-\
Dear Ms. Voigt:
below.
1

PSLF Program.
Program.
Sine b)(6)
Jeff ;raKer,;uIrector
Poli y Liaison and Implementation
Federal Student Aid

To; ~
Subject: Fw: American Immigration Lawyers Association
Date: Monday, June 30, 2014 11 :26:47 AM
(b)(5)
----- forwarded by Diane Freundel/PHEAA on 06/30/2014 11:25 AM-----
From: publicservice <public~ervice@ed.guv>

To: "FedLoan PSLF" <FedLuanPSLF@pheaa.org>
Cc: public~ervice <publicservice@ed.gov>
Date: 06/10/2014 02:14 PM
Subject: RE: American Immigration Lawyers A~suciatiun
Sun")' for the ddayj (b_l_(5_1_~

0
-----Original Mes~age-----
From: Diane Freundel [mailto:dfrcundc(ii:·phcaa.ori;l On Behalf Of FedLoan PSLF
Sent: Wednesday, May 07, 2014 12:12 PM
To: FedLuan PSLF
Cc: publicservice
Subject: Re: American Immigration Lawyers A~suciation
(b)(5)
Diane

To: public serv ice@ed.gov
Date: 05/06/2014 10:01 AM
Subject: Public: American Immigration Lawyer~ Association
Sent by: Diane Freundel
(b)(5)
(b)(5)
(See attached file: American Immigration Lawyers Association.7ip)
Diane Freundel
Compliance Services
(717)720-12fi7
fax- (717) 720-3911
dfreunde@pheaa.org
This me,,age contaim privileged and confidential information intended for

the ahove addressees only. If you receive thi, me,sage in error please
delete or destroy thi, message and/or attachment,.
The sender of this me<;<;agewill fully cooperate in the civil and criminal
prmecution of any individual engaging in the unauthorized use of this
message.
This me<;<;agecontaim privileged and confidential information intended for the ahove addressee, only. If you
receive this me,sage in error please delete or de,troy this me<;<;ageand/or attachments.
The sender of this me<;<;agewill fully cooperate in the civil and criminal prosecution of any individual engaging
in the unauthorized me of this message.
From: Foss Ian

To; Baker,Jeff
Cc: l.J..tL....J..Q:
Garofano Tamy
Subject: PSLF Letter - Immigration Lawyer Assoc1at1on
Date: Thursday, July 17, 2014 4:05:00 PM
Attachments: PSLF AILA 20140717 Foss.docx
H1Jeff,
(b)(5)
Ian
Page 461 o of 7666
(bi(51
Page 4611 of 7666
(bi(51
From: Foss Ian

To; Baker,Jeff
Subject: PSLF Letter for Immigration Lawyers
Date: Friday, November 07, 2014 3:24:00 PM
Attachments: PSLF AILA 201411 06 docx
H1Jeff,
(b)(5)
Ian
Page 4613 of 7666
(bi(51
Page 4614 of 7666
(bi(51
Page 4615 of 7666
(bi(51
Page 4616 of 7666
(bi(51
Page 4617 of 7666
(bi(51
Page 4618 of 7666
(bi(51
Page 4619 of 7666
(bi(51
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(bi(51

To; p11blicservice
Subject: PW American Immigration LawyersAssociation
Date: Tuesday, May 06. 2014 10:01 :54 AM
PSLF_May_06
thanks
Diane
This message contains privileged and confidential information intended for the above addressees only. If you
receive this message in error please delete or destroy this message and/or a\lachments.
The sender of this message will fully cooperate in the ci vii and criminal pro~ecution of any individual engaging
in the unauthorized use ofthi~ message.
From: Foss Ian

To; l(b)(6)
Cc: Dowling Maureen; McLarnon Gail; Moran Pamela: Arnold Nathan; Smith Brian; l.J.tL..k!J:l
Subject: Public Service Loan Forgiveness El1gib1lt1y
of the American Immigration Lawyers Assoc1at1on
Date: Wednesday, December 10, 2014 3:30:00 PM
Dear Ms. l(b)(6) I

Kind regards,
Ian Foss
Federal Student Aid

1 iJ 201-\
Dear Ms.~
below.
1

PSLF Program.
Program.
Sincerely, , /I
(b)(6)
J " ,
Polity Liaison and Implementation
Federal Student Aid
From: Mclarnon Gail

To; ~
Cc: l.l.1L...J..Q.n;
Moran Pamela; Ninemire Sandra
Subject: RE: Eligible employment/Public Service Loan Forgiveness Program
Date: Tuesday, June 19, 2012 12: 11 :49 PM
Th;rnks, Ian
From: Foss, Ian

Sent: Tuesday, June 19, 2012 11 :06 AM
To: Mclarnon, Gail
Subject: Re: Eligible employment/Public Service Loan Forgiveness Program
(b)(5)
On Jun 19, 2012, at 10:50, "McLarnon, Gail" <Gail.McLarnon@ed,gov> wrote:

(b)(5)

To: Mclarnon, Gail
(b)(5)
.\iaurL'cn
\lamccn Dm,-lmg, 1·.d. D.

I )ircctcJr
( )fficc cJf \:(Jn-Puhhc l ·.ducati(i11
( ) ffi cc c Jf l rn H l\"'1 th Jll a ml I rnpn in·rn c1lt
l '.S. Dcp:1.rtrnu11 (>fl .duc:i.ti( m
·11111 .\Ian land .hu1uL', S\\
\\ ashington, DC 21121!2
(21!2) 2W ....,821!
1TUUnTn dmylinl'IJ'"l,,cd
vm·
Join the ONPE listscrd
~~~~: Jri~~~'.bj~~IJ(~i
61
, 2U:;:;::2:05
AM II
Hi Ms. Dowling,
which is a 501 (c)(6) organization. Do you have any ideas where I could
go to find an answer to my question? None of the information that I've
seen on the website or that I've gathered from talking with customer
service individuals seems conclusive. I've even looked through the
statutes and regulations, which seem to indicate it would qualify, but I'm
not sure. I have included below some background information on both
AILA and my position, but please feel free to let me know if you need
!(b)(6) I
national association of immigration lawyers established to promote
justice, advocate for fair and reasonable immigration law and policy,
advance the quality of immigration and nationality law and practice, and
enhance the professional development of its members. AILA has over
11,000 attorneys and law professors members who practice and teach
immigration law. AILA Member attorneys represent U.S. families seeking
permanent residence for close family members, as well as U.S.
businesses seeking talent from the global marketplace. AILA Members
also represent foreign students, entertainers, athletes, and asylum
seekers, often on a pro bona basis. Founded in 1946, AILA is a
nonpartisan, not-for-profit organization that provides continuing legal
education, information, professional services, and expertise through its 36
chapters and over 50 national committees.

the board of governors to set and achieve liaison goals, and works with
coalition groups, responds to member questions, coordinates information
other Internet-based dissemination programs. The Liaison and
Information Associate provides support to designated AILA liaison

committees, and coordinates assistance to AILA members with respect to
information needs. The Liaison and Information Associate maintains
contact with various agencies, monitors administrative developments, and
seeks answers to member questions/problems.
From: Foss Ian

To; Baker ,Jeff: Garofano Tamy: Hammond Cynthia
l.J..tL....J..Q;
Subject: RE: Loan Issues
Date: Thursday, November 20, 2014 4:44:00 PM
Attachments: Loan Issues Meeting 20141121 docx
Alignment 20140516.docx
PSLF AILA 20141106.docx
RE ,Joint Consolidations.msg
Sec attached for an agenda and associated documents
-----Original Appointment-----
From: Foss, Ian
Sent: Thursday, August 28, 2014 3:35 PM
To: Foss, Ian; Utz, Jon; Baker, Jeff; Garofano, Tamy; Hammond, Cynthia
Subject: Loan Issues
When: Friday, November 21, 2014 10:00 AM-11 :00 AM (UTC-05:00) Eastern Time (US & Canada).
Where: Jeff's Office
This will be our new date and time for the meeting.
Page 4637 of 7666
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Baker, Jeff
From:Baker, Jeff
Sent: 19 Nov 2014 21 :59:32 -0600
To:Hardy, Eric
Cc:Foss, lan;Utz, Jon
Subject:RE: Joint Consolidations
l(b)(5) I
From: Hardy, Eric
Sent: Tuesday, November 18, 2014 1:52 PM
To: Baker, Jeff
Subject: Joint Consolidations
Jeff,
(b)(5)
I can come by and chat later or tomorrow if you prefer.
Thanks,
Eric
Eric Hardy
Systems Integration Division
Business Operations
Federal Student Aid
202-377-4560 (office)
eric.hardy@ed.gov
From: Foss Ian

To; Baker,Jeff
Garofano Tamy
Subject: RE: PSLF Letter - Immigration Lawyer Association
Date: Monday, August 25, 2014 10:19:00 AM
Attachments: PSLF AILA 20140825 Foss.docx
Th;rnks, Jeff See att,1rhed
From: Baker, Jeff

Sent: Friday, August 22, 2014 6:14 PM
To: Foss, Ian
Cc: Utz, Jon; Garofano, Tamy
Subject: RE: PSLF Letter - Immigration Lawyer Association
Try Lhis for Lhe nexl drafL
Ian. What was the other document you wanted me to look at?
From: Foss, Ian

Sent: Thursday, July 17, 2014 4:06 PM
To: Baker, Jeff
Cc: Utz, Jon; Garofano, Tamy
Subject: PSLF Letter - Immigration Lawyer Association
H1Jeff,
(b)(S)
Ian
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From: Utz Jon

To; ~
Cc: Smith Brian; Arnold Nathan: McLarnon Gail: Moran Pamela
Subject: RE: Public Service Loan Forgiveness Program (AILA)
Date: Thursday, November 06, 2014 9:18:27 AM
I have ju~t one minor formatting comment. The name of the employment certification form i~ italicized everywhere
except for one place in the 4th paragraph on page 1.
-----Original Message-----
From: Fo~~. Ian
Sent: ThuViday, November 06, 2014 9:06 AM
To: Moran, Pamela: Utz, Jon
Cc: Smith, Brian; Arnold, Kathan; McLarnon, Gail
Thank~, Pam. Here\ a cleaned up copy. Does anyone else plan on commenting!reviev>'ing?
From: Moran. Pamela
Sent: Wedne~day, November 05. 20144: 10 PM
To: Foss, Jan: Utz, Jon
(b)(5)
From: Fo~~. Ian
Sent: Wednesday, November 05, 2014 3:26 PM
To: Muran, Pamela: Utz, Jon
Cc: Smith. Brian: Arnold, Kathan: McLarnun. Gail
Subject: RE: Public Service Loan Forgivene~~ Program (AILA)
I think Jon'~ edits were the latest. See attached.
From: Moran, Pamela
To: Foss, Jan: Utz. Jon
Is that the draft you sent in response to Gail'~ reque~t ur something more recent''
From: Foss, Ian
To: Muran, Pamela: Utz, Jon
Thank~, Pam. Do you, or doe~ anyone else at OPE, plan on reviewing the language of the letter itself.'
From: Moran. Pamela
Sent: ThuViday, October 23, 2014 4:37 PM
To: Utz, Jon; Fo~~. Ian
(b)(5)
From: Utz. Jon
To: Foss, Jan
Cc: Smith, Brian; Arnold, Kathan; McLarnon, Gail: Moran, Pamela
(b)(5)
Frorn: Arnukl. Kathan
Sent: Thurs<lay, October 16, 2014 4:10 PM
To: Foss, Jan: McLarnon, Gail: Moran, Pamela
Cc: Utz, Jon; Smith. Brian; Arnold. Nathan
(b)(5)
(b)(5)
From: Fos,, Ian

Sent: Thursday,Octoher lfi,2014 11:11 AM
To: Arnold, Nathan; McLarnon, Gail, Moran, Pamela
Cc: Ut7, Jon: Smith, Brian
(b)(5)
What do otheVi think')
From: Arnold, Kathan
Sent: ThuViday, October 16, 2014 10:36 AM
To: Foss, Jan: McLarnon. Gail; Moran. Pamela
Cc: Utz, Jon; Smith, Brian: Arnold, Nathan
(b)(5)
From: Fos,, Ian
Sent: Thursday, October lfi, 2014 8:58 AM

To: McLarnon, Gail, Moran, Pamela
Cc: Ut7, Jon: Smith, Brian; Arnold, Nathan
crb,:.~:n'.~[{T>Till>,>TIIITIQTIIC=cnoTil!TIIITIIIOCTIIIT[SC.------------"I
here i, our draft of the letter. Let me know how you would

Sent: Wednesday, July 16, 2014 3: 15 PM
To: Foss, Ian
Cc: Ut7, Jon: Smith, Brian; Moran, Pamela
rm fine with that, thank,.
From: Fos,, Ian

To: McLarnon, Gail
Subject: Re: Public Service Loan Forgivenes, Program
(b)(5)
From: <Dowling>, Maureen <Maureen.Dowling@ed.gov<mailto: Maureen. DowlinlJ (ded.lJOV>>

Date: Wednesday, July 16, 2014 at 14:14
To: "McLarnon, Gail" <Gail.McLarnon@ed.gov<mailto:Ga1l.McLarnon(d)ed.lJOV>>, Ian Fos,
< ian. foss@ed.gov<mai 1to: ian. fo~s(d)ed.lJOV>>
Cc: "l;tz, Jon" <Jon.l;tz@ed.gov<mailto:.Jon.Lt7(ded.lJm'>>, "Smith, Brian"
<Brian.Smith@ed.gov<mailto: Brian.Smith(rued. ~ov>>, "Moran, Pamela"
<Pamela. Moran@ed .gov<mai 1to: Pamela. I\.1oran (a"\ed.lJOV>>
Gail and Ian,

(b)(5)
\Vould like to discuss th1, with you.
Maureen
Maureen Dowling, Ed. D.

Director
Office of Non-Puhlic Education and
Military Affairs Team
Office of Innovation and Improvement
400 Maryland Avenue, SW
Washington, DC 20202
(202) 260- 7820
maureen .dowl ing@ed .gov<mai 1to: mauree n.dow 1in~ (d ed. ~ ov>
/ ahoutioffice~/1 ist/ o i1/nonpuh 1ic/ onpe, i ~ n up. htm 1>!
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. lJOV
Suhscrihe to 011 news here<https:llpuhl1c.llovdel1verx.com/accounts/USED/<iuhscriher/new' topic id-USED

1 14> or
follow us on Twitter:@ED_Oll<http~:lltv,iitter.com1ED Oil>.

Sent: Wednesday, July 16, 2014 1:35 PM
Cc: Ut7, Jon: Smith, Brian; Moran, Pamela; Foss, Ian
(b)(5)
Plea,e contact Ian Fos, rn FSA 1t you have further quest10m. Thank,,
Gail McLarnon
Acting Senior Director, Policy Coordination, Development and Accreditation Service Department of Education
202-219- 7048
gai 1.mclarnon@ed.gov<mai 1to: ~ ai 1.me larnon (a"\ed.llov>

To: McLarnon, Gail
Hi, Gail.
Hope your time away was good.
I just wanted to touch hase on thi, inquiry and see if there i, any update.
Maureen

Sent: Monday, June 30, 2014 11: 15 AM
To: Dowling, Maureen: l;tz, Jon, Smith, Brian: Moran, Pamela; Foss, Ian
Maureen, I am out of the office until Wednesday. I will follow up with you when I return.
From: Dowling, Maureen<mailto:Maureen. Dowlin~ (ci)ed.~ov>

Sent: 613012014 8:08 AM
To: McLarnon, Gail<mailto:Gail.McLarnon(a"\ed.llov>
Subject: FW: Public Service Loan Forgivene'i'i Program Dear GaiL
Hello! It has heen a while since I have contacted you hut I am hoping you might he ahle to offer ,ome guidance.
(b)(5)
(b)(5)
Maureen

Director
(202) 260- 7820
maureen .dowl ing@ed .gov<mai 1to: mauree n .dow 1in~ (d ed. ~ ov>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. llov/ ahoutioffice~/1 ist/ o i1/nonpuh 1icl onpe, i ~ n up. htm 1>!
Suhscrihe to 011 news here<https:/ipuhl!c.llovdel!ve1)".COm/accounts/USEDi,uhscriher/new' 1topic id USED 14> or
follow us on Twitter:@ED_Oll<http~://tv,iitter.com/ED Oil>.
From: liliiill:Jl(b)(6) l~(b~)(~6)

________ ~
Sent: Sunday, June 29, 2014 I :22 PM
Subject: Re: Puhlic Service Loan Forgivenes, Program
Hi Ms. Dowling!
I hope you're well and getting to enjoy the summer! rm writing to follow up on this email string from forever ago,
in the hopes you have some advice. I'm not ,ure if you remember, hut I had contacted you ahout whether my
position as a Liaison Associate at the American Immigration Lawyers A,sociation would count as qualifying
employment for the Puhlic Service Loan Forgiveness Program. You were very kind and forwarded my email to
your colleagues at the Department of Education who work in that area.
My coworker has since applied to have my organization recognized as a qualifying organization (since we spoke,
there's heen an application process introduced hy which you can officially apply to have your current employment
count towards the necessary IO year, of qualifying employment). Unfortunately, the application came hack and said
our organization didn't qualify. She called and asked for ,upervisory review, and I think they're looking into it.
The application didn't give a reason that our organintion didn't qualify.
rm wondering if you know whether there is any other way to have the reque,t reviewed'! I think there is an
Omhud,man for the program, so we will look into that option, as well. I know this i,n't the area you work in at the
Department of Education, hut I thought it wouldn't hurt to reach out! Any ,uggestion, you have for how we can
follow up on the application would he much appreciated. I've attached a copy of her application and the denial, in
the event that ifs helpful.
Thank, ,o much! Hope to ,ee you soon.
Best.
liliilll
On Mon, Jun 25, 2012 at 10:36 PM, liliMJl(b)(6) I(b)(6) wrote:
Hi Ms. Dowling,
Thank you so very much! Thi, is really helpful. I had many of the same thought, a, your colleagues, hut it is so
rea,suring to hear that others are on the ,ame page.
Hope all i, well!
Best,
liliilll
<Maureen. Dow 1ing@ed.gov<mai 1to: Maureen. Dow 1i11~ (d ed. ~ ov> > wrote:
Dear l(b)(6JI
Thank, for your patience while I consulted with my colleagues in the Federal Student Aid Office regarding your
inquiry. Following is there respon,e to your question. Please let me know if I can he of further a,,istance.
All the hest,
Maureen

Director
Office of Non-Puhlic Education
(202) 260- 7820<tel:%28202%29%20260- 7820>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. llov/ ahoutioffice~/1 ist/ o i1/11onpuh1icl 011pe,i ~ 11up. htm 1>!
Sent: Wednesday, June 20, 2012 11:18 AM
Cc: Foss, Ian: Moran, Pamela; Ut7, Jon: Smith, Brian
Hi Maureen, In order to qualify for puhlic service loan forgiveness, a borrower must. among other requirements, he
employed full-time hy a puhlic service organization. The policy staff in FSA and OPE believe that the American
Immigration Lawyers Association meets the definition of puhlic ,ervice organintion in 34 CFR 685.2 l 9(h) of the
regulations because it is a private organization that provides puhlic service,, it i, not a husines, organized for profit.
nor is it engaged in parti,an or religious activities. As a full-time employee of an eligible puhlic ,ervice
organization, Ms.~ ,ervice would he comidered eligible as long a, ,he meets the rest of the eligibility
requirements in 34 CFR 685.2 l 9(cJ. I am including a link to the regulations should she have further questions
ahout her eligibility. http:/.\vww .law .cornell.eduicfr/text/14/685.219
Gail
From: liliiillJl(b)(6) l~(b~)(~6)
__________________ ,_,
Sent: Friday, June(~-----------------------~

Subject: Puhlic Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the hlock
party on Monday! It', always so nice to make it out to my parents home and catch up with everyone.
I wanted to follow up with you on our discus,ion ahout the Puhlic Service Loan Forgiveness Program. I am trying
to find out whether my current position as a Liaison and Information Associate would count as qualifying
employment. I work for the American Immigration Lawyer, Association, which is a 50l(cJ(6) organization. Do
you have any ideas where I could go to find an answer to my question'! None of the information that I've ,een on
the website or that I've gathered from talking with customer service individuals ,eems conclmive. I've even looked
through the statutes and regulation,, which seem to indicate it would qualify, hut I'm not sure. I have included
helow some background information on hoth AILA and my position, hut please feel free to let me know if you need
liliilll
AILA: The American Immigration Lawyers Association (AILA) is the national a,,ociation of immigration lawyer,
e,tahli,hed to promote ju,tice, advocate for fair and reasonable immigration law and policy, advance the quality of
immigration and nationality law and practice, and enhance the profe,,ional development of its members. AILA has
over 11,000 attorneys and law professors members who practice and teach immigration law. AILA Memher
attorneys represent lJ .S. familie, seeking permanent residence for close family members, a, well a, lJ .S. husines,e,
,eeking talent from the global marketplace. AILA Members also repre,ent foreign students, entertainers, athletes,
and asylum seekers, often on a pro hono hasi,. Founded in 1946, AILA is a nonparti,an, not-for-profit organintion
that provides continuing legal education, information, professional services, and expertise through its 36 chapter,
and over 50 national committees.
Position Description: The Liaison and Information Department provides direction to and coordination of agency
liai,on efforts, conducts suh,tantive legal research and analy,is, and gathers and di,seminate, information to
members and the puhlic. The Liaison and Information Department works with liai,on committee,, the executive
committee and the hoard of governor, to set and achieve liaison goals, and works with government agencies to
achieve those goals in close coordination with other internal functions, including Advocacy, Communications, and
the LAC and IPC. The department also coordinates AILA participation in coalition groups, responds to memher
questiom, coordinates information gathering and dissemination, and develops and manages lnfoNet and other
Internet-based dis,emination program,. The Liaison and Information A'i'iociate provides support to designated
AILA liaison committees, and coordinate, a,sistance to AILA members with respect to information needs. The
Liaison and Information Associate maintains contact with various agencies, monitor, administrative developments,
and seeks answer, to member gue,tionslprohlems.
lifil@[(bj(6j]
Kate Voigt
From: Foss Ian

To; Moran Pamela: l..!1L...J..Q.n
Cc: Smith Brian; Arnold Nathan: McLarnon Gail
Attachments: PSLF AILA 20141106.docx
Thank,, Pam. Here's a cleaned up copy. Does anyone else plan on commenting/reviewing'!
From: Moran. Pamela
Sent: Wedne,day, November 05. 20144: 10 PM
(b)(5)
From: Fo,,. Ian
Sent: Wedne,day, November 05. 2014 3:26 PM
I think Jon's edit, were the latest. See attached.
From: Moran. Pamela
Is that the draft you ,ent in respome to Gail's request or ,omething more recent?
From: Fo<;<;, Ian
Thank,, Pam. Do you, or doe, anyone else at OPE, plan on reviewing the language of the letter itself.'
From: Moran. Pamela
Sent: ThuT'iday, October 23, 2014 4:37 PM
To: Utz, Jon; Fo<;<;,
Ian
Page 4656 of 7666
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Page 4658 of 7666
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(b)(5)
From: Utz. Jon
To: Foss, Jan
(b)(5)
-----vngma1 ,.. essage-----

From: Arnold. Kathan
Sent: ThuViday, October 16, 2014 4: 10 PM
Cc: Utz, Jon; Smith. Brian: Arnold, Nathan
(b)(5)
From: Fos,, Ian

Sent: Thursday.October lfi,2014 11:11 AM
Subject: RE: Puhlic Service Loan Forgiveness Program (AILA)
(b)(5)
What do othef'i think')
Sent: Thur'iday, October 16, 2014 10:36 AM
(b)(5)
From: Fo,,. Ian

Sent: Thur'iday, October 16, 2014 8:58 AM
To: McLarnon. Gail; Moran. Pamela
(b)(5)
here i'i our draft of the letter. Let me knO\v hmv you would
~------------------~
like to handle comment,.

To: Foss, Ian
From: Fos,, Ian

To: McLarnon, Gail
(b)(5)

<Brian.Smith@ed.gov<mailto: Brian.Smith(d)ed. ~ov>>, "Moran, Pamela"
<Pamela. M oran@ed .gov<mai 1to: Pamela. I\.1oran (a"\ed.lJOV>>
Gail and Ian,

(b)(5)
Would like to discuss thi, with you.
Maureen

Director
Office of Non-Public Education and
(202) 260- 7820
/ aboutioffice~/1 ist/ o i1/nonpub 1ic/ onpe, i ~ n up. htm 1>!
Subscribe to 011 news here<https://publ1c.lJOVdel1ve1)".COm/accounts/USED.\ubscriber/new' 1topic id-USED 14> or
follow us on Twitter:@ED_Oll<http~://t\vitter.com/ED Oil>.

(b)(5)
Plea,e contact Ian Fos, in FSA if you have further questiom. Thank,,
Gail McLarnon
202-219- 7048
gai 1.mclarnon@ed.gov<mai 1to: ~ ai 1.me larnon (a'\ed.~ov>

To: McLarnon, Gail
Suhject: RE: Puhlic Service Loan Forgiveness Program
Hi, Gail.
Maureen

To: Dowling, Maureen; l;tz, Jon, Smith, Brian; Moran, Pamela; Foss, Ian

Sent: 6/30/2014 8:08 AM
To: McLarnon, Gail<mailto:Gail.McLarnon@ed.~ov>
Suhject: FW: Puhlic Service Loan Forgivene'i'i Program Dear Gail,
Hello! It has heen a while since I have contacted you hut I am hoping you might he ahle to offer ,ome guidance.
(b)(5)
(b)(5)
Maureen

Director
(202) 260- 7820
From: liliiill:Jl(b)(6) ll(b)(6)

~~--------- I
Hi Ms. Dowling!
Best.
liliilll
On Mon, Jun 25, 2012 at 10:36 PM, liliMJl(b)(6) lc(b~)~(6~)
________ ~lt~n~,(~b)~(6~)
______ ~wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
liliilll

Dear l(b)(6JI
All the hest,
Maureen

Director
Office of Non-Public Education
(202) 260- 7820<tel:%28202%29%20260- 7820>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. ~ov / ahoutioffice~/1 ist/ o i1/11onpuh1icl 011pe,i ~ 11up. htm 1>!
Hi Maureen, In order to qualify for public service loan forgiveness, a borrower must. among other requirements, he
employed full-time hy a public service organization. The policy staff in FSA and OPE believe that the American
regulations because it is a private organization that provides public service,, it i, not a husines, organized for profit.
about her eligibility. http:/.\vww .law .cornell.eduicfr/text/14/685.219
Gail
I
cc'-====----------~
From: liliiillJl(b)(6) (b)(6)
Sent: Friday,June01,201212:05AM

Subject: Public Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the block
I wanted to follow up with you on our discus,ion about the Public Service Loan Forgiveness Program. I am trying
below some background information on both AILA and my position, hut please feel free to let me know if you need
-Kate
AILA: The American Immigration Lawyers Association (AILA) is the national a,sociation of immigration lawyer,
immigration and nationality law and practice, and enhance the profe'i'iional development of its members. AILA has
over 11,000 attorneys and law professors members who practice and teach immigration law. AILA Member
and asylum seeker,, often on a pro hono hasi,. Founded in 1946, AILA is a nonparti,an, not-for-profit organintion
lifil@[(bj(6j]
Kate Voigt
K•,ra Vaiot
From: Foss Ian

Date: Wednesday, November 05, 2014 3:26:00 PM
Attachments: PSLF AILA 20141016 JU edits 20141023.docx
I think Jon's edit, were the latest. See attached.
From: Moran. Pamela
Is that the draft you ,ent in respome to Gail's request or ,omething more recent?
From: Fo,,. Ian
Thank,, Pam. Do you, or doe, anyone else at OPE, plan on reviewing the language of the letter itself.'
From: Moran. Pamela
Sent: Thur'iday, October 23, 2014 4:37 PM
To: Utz, Jon; Fo<;<;,
Ian
Sub·ect: RE: Public Service Loan For iveness Pro ram AILA
(b)(5)
From: Utz. Jon
Sent: Thur'iday, October 23, 2014 2:25 PM
To: Foss, Jan
(b)(5)
(b)(5)
-----Ongrnal Message-----
From: Arnold, l\"athan
Sent: Thursday, October I fi, 2014 4: 10 PM
To: Foss, Ian; McLarnon, Gail, Moran, Pamela
(b)(5)
From: Fo~~. Ian

Sent: ThuViday, October 16, 2014 11· 1 I AM
To: Arnold, Nathan: McLarnon. Gail; Moran, Pamela
Cc: Utz, Jon; Smith, Brian
(b)(5)
(b)(5)
What do others think'!
From: Arnold, l\"athan
Sent: Thursday, October 16, 2014 10:16 AM
To: Foss, Ian; McLarnon, Gail, Moran, Pamela
Cc: Ut7, Jon; Smith, Brian; Arnold, Nathan
Subject: RE: Puhlic Service Loan Forgiveness Program (AILA)
(b)(5)
From: Fos,, Ian

Sent: Thursday, October 16, 2014 8:58 AM
Cc: Utz, Jon; Smith, Brian; Arnold, Nathan
1(b"l:.~.;'IO~ll'U"11tmu>encmom1tmnmll"e"ll"I~-.
0 ----------~lhere i'i our draft of the letter. Let me knO\v hmv you would

Sent: Wedne,day, July 16, 2014 3: 15 PM
To: Foss, Jan
Cc: Utz, Jon; Smith, Brian; Moran, Pamela
I'm fine with that, thank,.
From: Fo<;<;,Ian
Sent: Wedne,day, July 16. 2014 3: 14 PM
To: McLarnon. Gail
Cc: Utz, Jon; Smith. Brian; Moran, Pamela
Subject: Re: Public Service Loan Forgivene'i'i Program
(b)(5)
From: <DO\vling>, Maureen <Maureen.Dowling@ecl.gov<rnailto:Maureen Dnwlini;@ed i;nv>>

< ian. foss@ed.gov<mai 1to: ian. fo~s(d)ed.lJ0V>>
Cc: "l;tz, Jon" <Jon.l;tz@ed.gov<mailto:.Jon.Lt7(deLLlJOV>>, "Smith, Brian"
<Brian.Smith@ed.gov<mailto: Brian.Smith(rued. ~ov>>, "Moran, Pamela"
<Pamela. M oran@ed .gov<mai 1to: Pamela. \1 oran (a"\ed.llov> >

Gail and Ian,

(b)(5)
Maureen

Director
(202) 260- 7820
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. !lOV/ ahoutioffice~/1 ist/ o i1/nonpuh 1icl onpe, i ~ n up. htm 1>!

(b)(5)
Gail McLarnon
202-219- 7048

To: McLarnon, Gail
Hi, Gail.
Maureen


Sent: 6/30/2014 8:08 AM
Suhject: FW: Puhlic Service Loan Forgivene'i'i Program Dear GaiL
(b)(5)
Maureen

Director
Wa,hington, DC 20202
(202) 260- 7820
rnaureen .dow Iing@ed.gov<rn a i Itn ·maureen .dnw Iin v@ed vnv>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. ~ov/ ahoutioffice~/1 ist/ o i1/nonpuh 1icl onpe, i ~ n up. htm 1>!
Suhscrihe to 011 news here<https:/ipuhl1c.~ovdel1ve1)".COm/accounts/USED.\uhscriher/new' 1topic id-USED 14> or
follow us on Twitter:@ED_Oll<http~://tv,,;itter.com/ED Oil>.
From: liliiill:Jl(b)(6)
llc(b~)(6~)---i:======='J0

Hi Ms. Dowling!
employment for the Public Service Loan Forgiveness Program. You were very kind and forwarded my email to
our organization didn't qualify. She called and asked for supervisory review, and I think they're looking into it.
the event that it's helpful.
Best,
liliilll
On Mon, Jun 25, 2012 at 10:36 PM, liliMJl(b)(6) I(b)(6) wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
-Kate

Dear Kate,
All the hest,
Maureen

Director
(202) 260- 7820<tel:%28202%29%20260- 7820>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. ~ov / ahoutioffice~/1 ist/ o i1/11onpuh1ic/ 011pe,i ~ 11up. htm 1>!
Cc: Foss, Ian: Moran, Pamela; Utz, Jon: Smith, Brian
Hi Maureen, In order to qualify for public service loan forgiveness, a harrower must. among other requirement,, he
nor i, it engaged in parti,an or religious activitie,. As a full-time employee of an eligible puhlic ,ervice
about her eligibility. http:/.\vww .law .cornell.edulcfrltext/141685.2 l 9
Gail
From: liliiillJl(b)(6) l~(b_:;1(-"6)~------------------'

Subject: Public Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the hlock
I wanted to follow up with you on our discus,ion ahout the Public Service Loan Forgiveness Program. I am trying
-Kate
and asylum seeker,, often on a pro hono hasi,. Founded in 1946, AILA is a nonparti,an, not-for-profit organintion
that provides continuing legal education, information, professional services, and expertise through its 36 chapters
members and the public. The Liai,on and Information Department \vorks with liai,on committee,, the executive
committee and the board of governors to set and achieve liaison goah. and work, with government agencies to
achieve tho,e goah in close coordination with other internal functions, including Advocacy, Communications, and
the LAC and JPC. The department also coordinates AILA participation in coalition group,, re,ponds to member
questiom, coordinates information gathering and dissemination, and develops and manage, lnfoNet and other
Jnternet-ba,ed di'i'iemination program,. The Liaison and Information A,,ociate provides support to designated
AILA liaison committees, and coordinates assi,tance to AILA member'i with re,pect to information need,. The
Liaison and Information A'i'iociate maintains contact with various agencies, monitor, admini,trative development,.
and seeks answer, to member que,tionsiproblems.
Kate Voio-t
(b)(6)
lifililllR§ei]
K '!le Voiot
Page 4674 of 7666
(bi(51
Page 4675 of 7666
(bi(51
From: Foss Ian

Date: Wednesday, November 05, 2014 3:21 :00 PM
Thank~, Pam. Do you, or doe~ anyone else at OPE, plan on reviewing the language of the letter itself.'
From: Moran. Pamela
To: Utz, Jon; Fo~~. Ian
(b)(5)
From: Utz. Jon
To: Foss, Jan
(b)(5)
From: Arnukl. Kathan

Sent: Thurs<lay, October 16, 2014 4:10 PM
To: Foss, Jan: McLarnon, Gail: Moran, Pamela
(b)(5)
(b)(5)
From: Fos,, Ian

(b)(5)
(b)(5)
From: Fos,, Ian

l
,.(b·)·(·5·)·
..
•·•··•··~··-"•""""""n-c••
"""""""""""'------------~ Ihere i, our draft of the letter. Let me know how you would
Sent: Wednesday, July lfi, 2014 3: 15 PM
To: Foss, Ian
From: Fos,, Ian

To: McLarnon, Gail
(b)(5)

Date: Wednesday, July lfi, 2014 at 14:14
<Pamela. Moran@ed .gov<mai 1to: Pamela. 1\.1 oran (a"\ed.lJ0V>>
Gail and Ian,

(b)(5)
Maureen

Director

(202) 260- 7820

Suhject: RE: Public Service Loan Forgiveness Program
(b)(5)
Gail McLarnon
202-219- 7048

To: McLarnon, Gail
Hi, Gail.
Maureen

Sent: 6/30/2014 8:08 AM

To: McLarnon, Gail<mailto:Gail.McLarnon@ed.llov>
Suhject: FW: Puhlic Service Loan Forgivene,, Program Dear GaiL
(b)(5)
Maureen

Director
(202) 260- 7820
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. !lOV / ahoutioffice~/1 ist/ o i1/nonpuh 1ic/ onpe, i ~ n up. htm 1>!
Suhscrihe to 011 news here<https://puhl!c.llovdel!verx.com/accounts/USEDl,uhscriher/new' 1topic id USED 14> or
follow us on Twitter:@ED_Oll<http~://t\vitter.com/ED Oil>.
From: liliiill:Jl(b)(6) ll(b)(6) 11

Sent: Sunday, June~2"9". 02"d =====.J
0J;4=;c,;:,;:2;:l;;,;;N;;l
Suhject: Re: Puhlic Service Loan Forgivenes, Program
Hi Ms. Dowling!
in the hopes you have some advice. I'm not ,ure if you rememher, hut I had contacted you ahout whether my

Best.
liliilll
On Mon, Jun 25, 2012 at 10:36 PM, lili:iilll(b)(6) I(b)(6) wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
-Kate

Dear Kate,
All the hest,
Maureen

Director
(202) 260- 7820<tel:%28202%29%20260- 7820>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. llov/ ahoutioffice~/1 ist/ o i1/11onpuh1ic/ 011pe,i ~ 11up. htm 1>!
Subject: RE: Puhlic Service Loan Forgiveness Program
Hi Maureen, In order to qualify for puhlic service loan forgiveness, a harrower must. among other requirements, he
organization, Ms. Voigt', ,ervice would he comidered eligible as long a, ,he meets the rest of the eligibility
ahout her eligibility. http:/.\vww .law .cornell.eduicfr/text/14/685.219
Gail
From: Kate Voigt [~(b)(6) Fl
Sent: Friday,June01,201.!.12.05Alvl

Subject: Puhlic Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the hlock
liliilll
AILA: The American Immigration Lawyers Association (AILA) is the national a'i'iociation of immigration lawyer,
and seeks answer, to member que,tionsiproblerns.
L
(b)(6)
Kate Voigt
(b)(6)
From: Foss Ian

To; Arnold Nathan: McLarnon Gail: Moran Pamela
Cc: l.J..tL....J..o:
Smith Brian
Date: Thursday, October 16, 2014 11 :11 :00 AM
(b)(5)
Frorn: Arnukl. Kathan
Sent: Thurs<lay, Octuber 16, 2014 10:36 AM
To: Foss, Ian: McLarnon, Gail: Moran, Pamela
(b)(5)
From: Foss, Ian

Sent: Thurs<lay, October 16, 2014 8:58 AM
To: McLarnon, Gail: Moran, Pamela
(b)(5) here is our <lraftof the leUer. Let me know how you would
'cc-~-~-------------~
like tu handle comments.

To: Foss, Ian
From: Fos,, Ian

To: McLarnon, Gail
(b)(5)

<Pamela. M oran@ed .gov<mai 1to: Pamela. I\.1oran (a"\ed.lJOV>>
Gail and Ian,
(b)(5)
Maureen

Director
(202) 260- 7820
/ ahoutioffice~/1 ist/ o i1/nonpuh 1icl onpe, i ~ n up. htm 1>!
Subscribe to 011 news here<https:/ipuhl!c.lJOVdel!verx.com/accounts/USEDi,uhscriber/new' 1topic id USED 14> or

(b)(5)
Gail McLarnon
202-219- 7048
gai 1.mclarnon@ed.gov<mai 1to: ~ ai 1.me larnon (a'\ed.llov>

To: McLarnon, Gail
Hi, Gail.
I just wanted to touch base on thi, inquiry and see if there i, any update.
Maureen


Sent: 6/30/2014 8:08 AM
To: McLarnon, Gail<mailto:Gail.McLarnon@ed.llov>
Subject: FW: Public Service Loan Forgivene'i'i Program Dear Gail,
(b)(5)
(b)(5)
Maureen

Director
(202) 260- 7820
1::~unr~~l~-~
~:~ .i~:~l(~~~
t
1 1
20:;: ; :22 PM
Hi Ms. Dowling!
Best.
liliilll
On Mon, Jun 25, 2012 at 10:36 PM, liliMJl(b)(6) l,(b~)~(6~)
_________________ -r-'wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
-Kate

Dear l(b)(6JI
All the hest,
Maureen

Director
(202) 260- 7820<tel:%28202%29%20260- 7820>
Hi Maureen, In order to qualify for public service loan forgiveness, a borrower must. among other requirements, he
about her eligibility. http:/.\vww .law .cornell.eduicfr/text/14/685.219
Gail
I
From: liliiillJl(b)(6) (b)(6) (b)(6)

Subject: Public Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the block
I wanted to follow up with you on our discus,ion about the Public Service Loan Forgiveness Program. I am trying
below some background information on both AILA and my position, hut please feel free to let me know if you need
liliilll
e
lifililll
Kate Voigt
Kate Voigt
From: Arnold, Nathan

To; Bl&...!.a!:1;
McLarnon Gail; Moran Pamela
Smith Brian: Arnold Nathan
Date: Thursday, October 16, 201410:40:06 AM
(b)(5)
From; Fo~~. Ian

To: McLarnon. Gail; Moran. Pamela
5_1___________________
,(b_l_( Jhere i~ our draft of the letter. Let me knO\v hmv you would
like to handle comment~.

Sent: Wedne~day, July 16. 2014 3: 15 PM
To: Foss, Ian
Cc: Utz, Jon; Smith. Brian: Moran, Pamela
rm fine with that, thank~-
From: Fo~~. Ian

Sent: Wedne~day, July 16. 2014 3: 14 PM
To: McLarnon. Gail
Cc: Utz, Jon; Smith. Brian: Moran, Pamela
Subject: Re: Public Service Luan Furgiveness Prugrarn
(b)(5)
Frum: <Dowling>.Maureen<Maureen.Dowling@ed.gov<nwil111·Maurern Q11w)int•c?edt•(iy>>

Date: Wednesday, July 16. 2014 at 14: 14
To: "McLarnon.Gail"<Gai1.McLarnon@ed.gov<mai]tn:Gai1 McLarnnn(ci)ed liov>>, Ian Fo~~
<ian.fo~~@ed.gov<mailtn·ian fo~~(ci)ed-linv>>
Cc: "C"tz.Jon"<Jon.C"tz@ed.gov<rnail(()"lnn l:(1@ed i;nv>>. "Smith. Brian"
<Brian.Smith@ed.gov<rnailtn-Rrian Srnith@ed i;ov>>, "Moran, Pamela"
<Pame1a.Moran@ed.gov<rnailtn·Parnela Mnran@kd-linv>>
Gail and Ian,
(b)(5)
Would like to discuss thi~ with you.
Maureen
Maureen Dowling_ Ed. D.

Director
Office of Non-Public Education and
Military AffaiVi Team
Wa~hington_ DC 20202
(202) 260- 7820
maureen .dow Iing@ed.gov<rn a i Itn ·maureen .dnw Iin v@ed vnv>
Join the O1\"PE li~tserv<l1ttp:i/www1 ed.:;,m·/ahoutinffice~ili~t/oii/nnnp11hlic/onpe~i vnup.html> !
Subscribe to Oil new~ here<http~· /ipphlic :;,nvdeliver)'.cnrn/accnunt~/l TSED,\ub~criherinew' 1tnpic id=! JSF.D 14> or
follow u~ on Twitter: @ED_Oll<http~'/itwitter corn/ED 011>.

Sent: Wedne~day, July 16. 2014 I :35 PM
Cc: Utz, Jon; Smith_ Brian: Moran, Pamela: Foss_ Jan
(b)(5)
Plea~e contact Jan Fo~~ in FSA if you have further questiom. Thank~,
Gail McLarnon
Acting Senior Director_ Policy Coordination,
Development and Accreditation Service
202-219- 7048
gail.mclarnon@ed.gov<rnailtn-11ail rnclarnnn@led :;,nv>

Sent: ThuViday, July I 0. 2014 12: 18 PM
To: McLarnon. Gail
Hi_ Gail.
Hope your time away wa~ good.
I just wanted to touch ba~e on thi~ inquiry and ~ee if there i~ any update.
Maureen


Sent: 6/30/2014 8:08 AM
Subject: FW: Puhlic Service Loan Forgivene,, Program
Dear GaiL
(b)(5)
Maureen

Director
(202) 260- 7820
5_1______
From: Kate Voigt [r0n•"•"•'',j{_b_lt ~
Hi Ms. Dowling!
I hope you're well and getting to enjoy the summer! I'm writing to follow up on this email string from forever ago,
employment for the Public Service Loan Forgiveness Program. You were very kind and forwarded my email to
our organization didn't qualify. She called and asked for supervisory review, and I think they're looking into it.
Best.
-Kate
(b)(6)
On Mon.Jun 25, 2012 at 10:36 PM, Kate Voigt > wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
-Kate

Dear Kate,
All the hest,
Maureen

Director
(202) 260- 7820<tel:%28202%29%20260- 7820>
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. llov/ ahoutioffice~/1 ist/ o i1/11onpuh1icl 011pe,i ~ 11up. htm 1>!
Cc: Foss, Ian: Moran, Pamela; Utz, Jon: Smith, Brian
Hi Maureen, In order to qualify for puhlic service loan forgiveness, a harrower must. among other requirements, he
Immigration Lawyers Association meets the definition of public ,ervice organintion in 34 CFR 685.2 l 9(b) of the
nor is it engaged in parti,an or religious activities. As a full-time employee of an eligible public ,ervice
ahout her eligihility. http:/.\vww .law .cornell.eduicfr/text/:,4/685.219
Gail
From: Kate Voigt [lll.illlillJ(b)(6) pi
Sent:Friday,June01,20lj
~-----------------~
I
Suhject: Puhlic Service Loan Forgiveness Program
Hi Ms. Dowling,
It was really great seeing you at the hlock party on Monday! It's alway, ,o nice to make it out to my parent, house
and catch up with everyone.
I wanted to follow up with you on our discus,ion ahout the Public Service Loan Forgiveness Program. I am trying
-Kate
and asylum seeker,, often on a pro hono hasi,. Founded in 1946, AILA is a nonpani,an, not-for-profit organintion
that provides continuing legal education, information, professional services, and expertise through its 36 chapters
Position De,cription: The Liaison and Information Department provides direction to and coordination of agency
liai,on efforts, conducts sub,tantive legal research and analy,is, and gathers and di,seminate'i information to
members and the public. The Liai,on and Information Department \vorks with liai,on committee,, the executive
committee and the board of governors to set and achieve liaison goah. and work, with government agencies to
achieve tho,e goah in close coordination with other internal functions, including Advocacy, Communications, and
the LAC and JPC. The department also coordinates AILA participation in coalition group,, re,ponds to member
questiom, coordinates information gathering and dissemination, and develops and manage, lnfoNet and other
Jnternet-ba,ed di'i'iemination program,. The Liaison and Information A,,ociate provides support to designated
AILA liaison committees, and coordinates assi,tance to AILA member<; with re,pect to information need,. The
Liaison and Information A'i'iociate maintains contact with various agencies, monitor, admini,trative development,.
Kate Voigt
Kate Voigt
Kate Voigt
(b)(6)
From: Foss Ian

To; McLarnon Gail: Moran Pamela
Cc: l.J..tL....J..o:
SmithBrian: Arnold Nathan
Date: Thursday, October 16, 2014 8:58:00 AM
Attachments: PSLF AILA 20141016.docx
(b)(5)
here 1s our draft of the letter. Let me know
how you v,muld like to handle comments

To: Foss, Ian
I'm lir1e wilh lhal, Lhanks.
From: Foss, Ian

To: McLarnon, Gail
(b)(5)
From: <Dowling>, Maureen <Maureen.Dowling@ed.gov>

Date: Wednesday, July 16, 2014 at 14·14
To: "McLarnon, Gail" <Gail.McLarnon@ed.gov>, Ian Foss <ian.foss@ed.gov>
Cc: "Utz, Jon" <Jon.Utz@ed.gov>, "Smith, Brian" <Brian.Smith@ed.gov>, "Moran, Pamela"
<Pamela. Mora n@ed .gov>
Subject: RE· Public Service Loan Forgiveness Program
(b)(5)
.\l:1.urcu1
.\hurcc11 Dmd111g, l·.d. D.

!)1rcct!ir
( )fricc (Jf "t\cJ11-Puhl1C1·.duc1thJ11 and
.\lilitan \ff:1.ir~ T cam

( )ftlCL'()r ][1!1()\a(j()[l and lmpnl\'L'11lL'I1l
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\\·a\h111gtrn1, \)(" .2().211.2
(.211.2:1
.2W--k.211
maurrrn d(iwlinvfZDrd
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Join the ONPE listscrY!
.\·11/1.r,-1iil/'
lo ()ff 1/FiJ'S
/wn orjr,/loil' 11.rr,11"//1•1//r1:·iu;/ ,f) ()ff.
From: Mclarnon, Gail

Sent: Wednesday, July 16, 2014 1 :35 PM
Cc: Utz, Jon; Smith, Brian; Moran, Pamela; Foss, Ian
(b)(5)
Ple,1se rnnt,1rt l;rn Foss 1n FSA if you h,we further questions. Thanks,
Gail McLarnon
Aeling Senior Direclor, Policy Coordinalior1,
Department of [ducat1on
202-219-7048
gai I.mcl arnon@ed.gov

To: McLarnon, Gail
1!1, Cail.
.\l:1.urcu1

Sent: Monday, June 30, 2014 11 :15 AM
To: Dowling, Maureen; Utz, Jon; Smith, Brian; Moran, Pamela; Foss, Ian
From: Dowling Maureen

Sent: 6/30/2014 8:08 AM
To: McLarnon Gail
(b)(5)
.\l:1.urcu1
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

!)1rcct!ir
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\1.1hs1nhr /(J ( )// ih 11·s1\ 1-r (Jr /i1//(JJJ'11s11;1·111·/li(-r: (d / :/) ( )//.
From: Kate Voigt (-(b)(Bl ~

"':2"2-,P"M,------~
Sent: Sunday, June 29, 201'C1r-4n-1
Hi Ms. Dowling!
I hope you're well and getting to enjoy the summer! I'm writing to follow up on this email
string from forever ago. in the hopes you have some advice. I'm not sure if you remember,
but I had contacted you about whether my position as a Liaison Associate at the American
Immigration Lawyers Association would count as qualifying employment for the Public
Service Loan Forgiveness Program. You were very kind and forwarded my email to your
colleagues at the Depaitment of Education who work in that area,
My coworker has since applied to have my organization recognized as a qualifying
organization (since we spoke. there's been an application process introduced by which you
can officially apply to have your current employment count towards the necessary 10 years of
qualifying employment). Unfortunately, the application came back and said our organization
didn't qualify. She called and asked for supervisory review, and I think they're looking into
it, The application didn't give a reason that our organization didn't qualify.
I'm wondering if you know whether there is any other way to have the request reviewed? I
think there is an Ombudsman for the program, so we will look into that option, as well. I
know this isn't the area you work in at the Department of Education, but I thought it wouldn't
hurt to reach out! Any suggestions you have for how we can follow up on the application
would be much appreciated. I've attached a copy of her application and the denial, in the
event that it's helpful.
Best,
-Kate
0~ Mon, Jun_25, 2012 at 10:36 PM, Kate Voigt tb)(6J I> wrote:
H1 Ms, Dowlmg, ~--------~
Thank you so very much! This is really helpful. I had many of the same thoughts as your
colleagues. but it is so reassuring to hear that others are on the same page.
Hope all is well!
Best,
-Kate
On Wed. Jun 20, 2012 at 12:21 PM. Dowling. Maureen <Maureen,Dowling@ed.gov> wrote:
Dear h..:1.te,
Thanks for y()ur patience \Yhik I C()multnl \Yith rny C()lkagues 111tlw l·nkral Student .\id ()frice
regarding y(Hlf 1m1u1ry. l·(illcJ\\"ITlgIS there re\p(inse tcJ y(iur c1uesthJ11. Please kt me kncJ\\" 1f I c111
lx of further a\\l\tancc.
\II tlw best,
.\l:i.urL'Ul
.\l:1.ureu1 D( J\\ 1mg, l ·.d. D.

Director

( )ftlCL'()r lll!1()\a(j()[l and lmpnl\'L'11lL'I1l
l .S. Dq):1rtmu1l ()fl '.duc:7.tHm
•11!1!.\l:i.r~l:i.nd \\Ulllc. S\\
\\·a\h111gtrn1, \)(" .2().211.2
(202) 7(,() 7820
/'<JY
Join the ONPE listscrv!
From: :i\fcLarnon, Gail
Sent: \X,,ednesday,June 20, 2012 11:38 AM
Cc: Foss, Ian; Moran, Pamela; Utz,Jon; Smith, Brian
Hi Maureen, In order to qualify for public service loan forgiveness, a borrower must, among
other requirements, be employed full-time by a public service organization. The policy staff in
FSA and OPE believe that the American Immigration La'\vyers Association meets the definition
of public service organization in 34 CFR 685.219(b) of the regulations because it is a private
organi;,:ation that provides public services, it is not a business organi;,:ed for profit, nor is it
engaged in partisan or religious activities. As a full-time employee of an eligible public service
organization, Ms. Voigt's service would be considered eligible as long as she meets the rest of the
eligibility requirements in 34 CFR 685.219(c). I am including a link to the regulations should she
have further questions about her eligibility. http:/ /v.:w:w.Jaw.cnrnell.edufrfr/text/14/685.219
Gail
From: Kate Voigt [mailtol(b)(6J
Sent: Friday, June 01, 20~12~12~:~0~5~A~M~--~

Hi Ms. Dowling,
It was really great seeing you at the block party on Monday! It's always so nice to
make it out to my parents house and catch up with everyone.
~Kate

Kate Voigt
Kate Voigt
Kate Voigt
Page 4701 017666
(bi(51
Page 4702 of 7666
(bi(51
From: Foss Ian

To; l1lwllr!
Thank~. I fixed it.
From: UtL, Jun
Sent: Thurs<lay, November 06, 2014 9:18 AM
To: Foss, Ian
Cc: Smith, Brian: Arnol<l, Kathan: McLarnun, Gail: Moran, Pamela
I have just one minor formalling comment. The name ufthe employment certification form is italiciLe<leverywhere
except fur une place in the 4th paragraph on page I.
From: Fuss, Ian
Sent: Thurs<lay, November 06, 2014 9:06 AM
To: Muran, Pamela; Utz, Jon
Cc: Smith, Brian: Arnol<l, Kathan: McLarnun, Gail
Thanks, Pam. Here's a cleane<l up copy. Due~ anyone else plan on cummenting/reviewing?
From: Moran, Pamela
Sent: Wednes<lay, November 05, 2014 4: 10 PM
To: Foss, Ian: Utz. Jon
Cc: Smith. Brian: Arnol<l, Kathan: McLarnun. Gail
(b)(5)
From: Fuss, Ian
Sent: Wednes<lay, November 05, 2014 3:26 PM
To: Muran, Pamela; Utz, Jon
I think Jon'~ edits were the latest. See attached.
From: Moran, Pamela
Sent: Wednes<lay, November 05, 2014 3:25 PM
To: Foss, Ian: Utz. Jon
ls that the draft you sent in respon,e to Gail's request or something more recent'.'
From: Fos,, Ian
To: Moran, Pamela; Ut7, Jon
Cc: Smith, Brian, Arnold, l\"athan, McLarnon, Gail
Thank,, Pam. Do you, or doe, anyone else at OPE, plan on reviewing the language of the letter itself!
From: Moran, Pamela
To: Ut7, Jon: Fos,, Ian
Cc: Smith, Brian, Arnold, l\"athan, McLarnon, Gail
(b)(5)
From: Utz, Jon

To: Foss, Ian
Cc: Smith, Brian, Arnold, l\"athan, McLarnon, Gail: Moran, Pamela
(b)(5)
-----Ong1nal Message-----
From: Arnold. Kathan
Sent: ThuViday, October 16, 2014 4: 10 PM
(b)(5)
(b)(5)
From: Fos,, Ian

(b)(5)
(b)(5)
From: Fos,, Ian

(b)(5) here i, our draft of the letter. Let me know how you would
't"ik",-<o~h-,.-.,-d"l,-,-o-o_n_n-,-.,-"-
..------------~

To: Foss, Ian
From: Fos,, Ian

To: McLarnon, Gail
Subject: Re: Public Service Loan Forgivene'i'i Program
(b)(5)

Date: Wednesday, July lfi, 2014 at 14:14
<Pamela. Moran@ed .gov<mai 1to: Pamela. 1\.1 oran (a"\ed.lJ0V>>
Gail and Ian,

(b)(5)
Maureen

Director

(202) 260- 7820

(b)(5)
Gail McLarnon
202-219- 7048
gai 1.mclarnon@ed.gov<mai 1to: ~ ai 1.me larnon (a'\ed.~ov>

To: McLarnon, Gail
Hi, Gail.
Maureen


Sent: 6/30/2014 8:08 AM
Suhject: FW: Puhlic Service Loan Forgivene,, Program Dear GaiL
(b)(5)
Maureen

Director
(202) 260- 7820
Join the () I\"PE Iistserv<l1 ttp: i/W\\'\V2.ed. ~ov / ahoutioffice~/1 ist/ o i1/nonpuh 1ic/ onpe, i ~ n up. htm 1>!
Suhscrihe to 011 news here<https://puhl!c.~ovdel!verx.com/accounts/USEDl,uhscriher/new' 1topic id USED 14> or
From: Kate Voigt 1lllililill;f(b)(6)

Sent: Sunday, June 29, 20,TJ4~1~:2~2rn1~>Nrn1----~
Suhject: Re: Puhlic Service Loan Forgivenes, Program
Hi Ms. Dowling!
in the hopes you have some advice. I'm not ,ure if you rememher, hut I had contacted you ahout whether my
Best.
-Kate
On Mon,Jun 25, 2012 at 10:36 PM, Kate Voigt <(b)(6) > wrote:
Hi Ms. Dowling,
Hope all i, well!
Best,
-Kate

Dear Kate,
All the hest,
Maureen

Director
(202) 260- 7820<tel:%28202%29%20260- 7820>
Hi Maureen, In order to qualify for puhlic service loan forgiveness, a horrower must, among other requirements, he
employed full-time hy a puhlic service organization. The policy staff in FSA and OPE helieve that the American
Immigration Lawyers Association meets the definition of puhlic ,ervice organintion in 34 CFR 685.2 l 9(b) of the
regulations hecause it is a private organization that provides puhlic service,, it i, not a husines, organized for profit,
nor is it engaged in parti,an or religious activities. As a full-time employee of an eligihle puhlic ,ervice
ahout her eligihility. http:/.\vww .law .cornell.eduicfr/text/14/685.219
Gail
From: Kate Voigt l(b)(6)
Sent: Friday, June(") 1r,-2"t")Jr2~t"2":('b~A"M~------------------"

Suhject: Puhlic Service Loan Forgiveness Program Hi Ms. Dowling, It was really great seeing you at the hlock
-Kate
AILA: The American Immigration Lawyers Association (AILA) is the national a'i'iociation of immigration lawyer,
e,tahli,hed to promote ju,tice, advocate for fair and reasonahle immigration law and policy, advance the quality of
immigration and nationality law and practice, and enhance the profe'i'iional development of its memhers. AILA has
attorneys represent lJ .S. familie, seeking permanent residence for close family memhers, a, well a, lJ .S. husines,e,
lnternet-hased dis,emination program,. The Liaison and Information A'i'iociate provides support to designated
AILA liaison committees, and coordinate, a,sistance to AILA memhers with respect to information needs. The
Liaison and Information A,,ociate maintains contact with various agencies, monitor, administrative development,.
K'lle Voic..t
Kate Voigt
Kate Voigt
(b)(6)
From: Foss Ian

To; Dowling Maureen
Cc: l..!1L...J..o.!:
Smith Brian: Moran Pamela: McLarnon Gail
Date: Monday, November 24, 2014 8:43:00 AM
(b)(5)

Sent: Friday, November 21, 2014 4:12 PM
To: Foss, Ian
Cc: Utz, Jon; Smith, Brian; Moran, Pamela; Mclarnon, Gail
Dear Ian,
(b)(6)
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Director
( )ftlCL' ()r i\()[l Publ!C l.duc:i.ti(ll1 :i.nd
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From: Foss, Ian

Sent: Friday, November 21, 2014 1 :53 PM
Hi Marueen,
Sorry this took so long WP. h,wP. a f1n,1lizP.IP.ttn that 1srP.ady to bP.sP.nt to Ms Voigt S1ncP.you havP.
communicated with her, I assume you have her contact information. Could you pass that along so
that we can send direct the letter to her)
Th;rnks,
Ian

Sent: Thursday, August 21, 201412:06 PM
To: Foss, Ian; Mclarnon, Gail
1:7.n,
(b)(5)
.\!aurcv11
.\l:1.urcu1 D( J\\ 1mg, l '.d. D.

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From: Foss, Ian

Sent: Thursday, August 21, 2014 8:38 AM
To: Dowling, Maureen; Mclarnon, Gail

(b)(5)

(b)(5)

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From: Foss, Ian

Sent: Wednesday, August 20, 2014 4:43 PM
111Maureen,
I'm ':.0rry for Lhe delay. I've drafled a response arid il is in Lhe µroce':.S of being reviewed. I hope lhal
l.'./P.c;rn have thP. letter sent out soon
Ian

To: McLarnon, Gail; Foss, Ian
1 iust \\·anted to touch ha\c 011 th1s matter a\ katc \'rngt 111forrned rnc that \he has ll()t 1-cce1Yed
;u1y ccJrrespcJ11dc1ice regarding this n1attvr . .\light y(HI he ahk t(J kt me kncJ\\" the statu\ (Jfl'S \\
respcJ11\et
Th:i.nb,
.\l:1.urcu1

To: Dowling, Maureen; Foss, Ian
Maureen, FSAwill draft a letter from on this but we are happy to discuss.

(b)(5)
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
.\!ilnan· .\ff;ur\ ·1earn
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(b)(5)
Please contact Ian Foss in FSA if you have further questions. Thanks,
G,1il Mclarnon
1\cting Senior Director, Policy Coordination,
Deparlrnenl ol Educalior1
202-210-7048

To: Mclarnon, Gail
1 iust \\·anted to touch ha\c 011 th1s 1rn1u1ryand SlT 1f thvrc 1s any update .
.\!aurcc11


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)
.\!aurcc11

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(b)(6)
From: Kate Voigt [m ii
Sent: Sunday, June 29,v, ➔ .z:z:, ,v,
Hi Ms. Dowling!
I hope you·re well and getting to enjoy the summer! I'm writing to follow up on this email
string from forever ago. in the hopes you have some advice. rm not sure if you remember,
colleagues at the Depaitment of Education who work in that area.
it. The application didn't give a reason that our organization didn't qualify.
know this isn't the area you work in at the Department of Education, but I thought it wouldn ·t
Best,
fbJ(B) I J(b)(6) I
On Mon, Jun 25, 2012 at 10:36 PM, Kate Voigt 1 r wrote:
Hi Ms. Dowling. ~-------~
Hope all is well!
Best,
On Wed. Jun 20, 2012 at 12:21 PM. Dowling. Maureen <Maureen.Dowling@ed.gov> wrote:
!)car~
Thanks for y()ur patience \Yhik I C()multnl \Yith rny C()lkagucs 111tlw lTdcral Student .\id ()fricc
regarding y(Hlf 1m1u1ry. l·(illcJ\\'ITlg IS there re\p(inse tcJ y(iur lJUCSthJTl. Please kt me kncJ\\' 1f I c111
.\11 thL·best .
.\l:i.urL'Ul
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(202) 2!,0 7820
From: .i\kLarnon, Gail
Sent: \'<-'ednesday,June 20, 2012 11:38 AM
Cc: Foss, Ian; l\foran, Pamela; Utz,Jon; Smith, Brian
other requirements, be employed full~time by a public service organi;,:ation. The policy staff in
FSA and OPE believe that the American Immigration Lawyers Association meets the definition
of public service organization in 34 CFR 685.219(6) of the regulations because it is a private
organization that provides public services, it is not a business organized for profit, nor is it
engaged in partisa~ligious activities. As a full-time employee of an eligible public service
LJ
organi;,:ation, .i\fs. service would be considered eligible as long as she meets the rest of the
eligibility requirements 111 34 CFR 685.219(c). I am including a link to the regulations should she
have further questions about her eligibility. http:/ /\\"\v'\v.law.cornell.edu/cfr/text/34/685.219
Gail
From:l(bl(6 l l[mailto:Ll(b_l(_
61_____ ~
Sent: Friday, June 01, 201212:05 AM

Hi Ms. Dowling,
l(b)(6) I

----------------------------
~===ca-----------
(bJ(6J
Vnt 1 l!oiut
From: Foss Ian

To; Dowling Maureen
Cc: l..!1L...J..o.!:
Date: Friday, November 21, 2014 1:52:00 PM
Sorry this took so long We have a finalize letter that is ready to be sent to Ms Voigt Since you have
wmmunicaled vvilh her, I assume you have her conlacl inlormalion. Could you µass Lhal along so
that v,'f'. c;rn se.nr-Jdire.ct the. le.tte.r to he.r;i
Thanks,

Llll,
(b)(5)
.\l:1.urcu1
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From: Foss, Ian

(b)(5)
(b)(5)

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Director
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From: Foss, Ian

Hi Maureen,
I'm sorry for the delay. I've drafted a response and 1t 1sin the process of being reviev.,ied. I hope that
we can have the letter sent out soon


rcsp()n~c:'
Th:i.nks,
.\!aurcc11

M,1ureen, FSAwill draft a letter from on this but we are happy to discuss.

(b)(5)
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricc (Jf "t\cJ11-Puhl1e 1·.duc1thJn and
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(b)(5)
Gail McLarnor1
Acting Senior Director. Policy Coordin;it1on.
2U2-21'::l-70118
~ai I.mcl arnon@ed -~ov

To: McLarnon, Gail
1!1, Cail.
l [()pc \(JL!r time :7.\\:7.\ 11:1~ g()rnl.
.\!aurcv11


Sent: 6/30/2014 8:08 AM
To: McLarnon Gail
(b)(5)
.\l:1.urcu1
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

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From: Kate Voigt [m::iiltol(b)(Bl

Sent: Sunday, Jun~•orr1r4~1~:2~2~P"M~--~
Hi Ms. Dowling!
string from forever ago. in the hopes you have some advice. I'm not sure if you remember,
organization (since we spoke, there's been an application process introduced by which you
Best,
I
b
b)(6)
~l(b~)(~s1--~u
~ Mon, Jun_25, 2012 at 10:36 PM, n(b)(B) Fwrote:
H1 Ms. Dowlmg, ~--------~
Hope all is well!
Best,
Dearl(b)(6) I
Thanks f(>r 1(lllf pat1u1Ce 11hik l nm~ultul 1111h 1111C(1lk:1.gues l!1 thL' l;ukral Stucknt \id ( )ffice
reg:i.rdmg \(JL!r mqu1n. 1:(Jl1(1111I1g
1s therL' rL'~[)(!I1SL'l(l \(Jllr Lluesti(ll1. PkasL' kt me krn111 if l can
lx of further :t\\l\tancc.
\II tlw best,
.\!a11rcc11
.\l:1.ureu1 D( J\\ 1mg, l ·.d. D.

Director
( )ftlcL' ()r i\()[l Publ!C l.duc:i.ti(ll1
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maureen.Jowlino·(t/:e<l.f(l\.

engaged in partisan or relib-'1ousactivities. As a full-time employee of an eligible public service
organization, Ms.l(b)(6) !service would be considered eligible as long as she meets the rest of the
Gail
From:l(b)(B) railtol(b)(B) I,

Hi Ms. Dowling,
!(b)(6) I
its 36 chapters and over 50 nationalcommittees.

Liaisonand InformationDepartmentworks with liaisoncommittees,the executive
with governmentagencies to achieve those goals in close coordinationwith other
member questions,coordinatesinformationgathering and dissemination,and
to informationneeds. The Liaisonand InformationAssociate maintainscontactwith
various agencies, monitorsadministrativedevelopments,and seeks answers to
l(b)(6)
(b)(6)
I
(b)(6)
(b)(6) I
(b)(6)
From: Foss Ian

To; Dowling Maureen; McLarnon Gail
Cc: l..!1L...J..o.!:
Smith Brian: Moran Pamela
Date: Thursday, August 21, 2014 8:37:00 AM
(b)(5)

(b)(5)

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From: Foss, Ian

111Maureen,
I'm ':.0rry for Lhe delay. I've drafled a response arid il is in lhe µroce':.S of being reviewed. I hope lhal
v,'P.c;rn have thP. letter sent out soon
Ian

1 iust \\·a11ted to touch ha~c 011 th1s matter a~fbJ(6) j11forrned rnc that ~he has not 1-ccel\Td
;u1y ccJrrespcJ11dc1ice regarding this n1attvr . .\light y(HI he ahk t(J kt me kncJ\\' the statu~ (Jfl'S \\
respcJ11~et
Th:i.nb,
.\l:1.urcu1


(b)(5)
\\-()uld like to discuss th1s \\'Ith \"!lll,
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director

.\lilitan \ff:1.ir~ T c:i.m
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(b)(5)
Gail Mclarnor1
2U2-21'::l-70118

To: Mclarnon, Gail
1!1, Cail.
l [()pc \(JL!r time :7.\\:7.\ 11:1~g()rnl.
.\!aurcv11


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)
.\l:1.urcu1

!)1rcct!ir
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From: Kate Voigt [m"iltnl(b)(6) h

Sent: Sunday, June==s,',c· ===-~''
29, ~014 1 :22 PM
Hi Ms. Dowling!
I hope you·re well and getting to enjoy the summer! I'm writing to follow up on this email
know this isn't the area you work in at the Department of Education, but I thought it wouldn ·t
Best,
4(b)(6) I
On Mon, Jun 25, 2012 at 10:36 PM, p1( 5l ~(b)(Bl f> wrote:
Hi Ms. Dowling. . .
Hope all is well!
Best,
On Wed. Jun 20, 2012 at 12:21 PM. Dowling. Maureen <Maureen.Dowling@ed.gov> wrote:
Dear 1---:me,
Thanks for y()ur patience \Yhik I C()multnl \Yith rny C()lkagues 111tlw lTderal Student .\id ()frice
IS there re\p(inse
regarding y(Hlf 1m1u1ry. l·(illcJ\\'117.i-; tcJ y(iur c1uesthJ11. Please kt me kncJ\\' 1f I c111
.\11 thL·best .
.\l:i.urL'Ul
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.
Director
( )ftlCL'()r lll!1()\a(j()[l and lmpnl\'L'11ll'I1l
---1-!Hl
\\·a\h111gtrn1, \)(" .2().211.2
(202) 7(,() 7820
maurr:r:n .d( iwlmµIZDr:d.µ<J\"

organization, j\-fs~(b)( 6 l !service would be considered eligible as long as she meets the rest of the
eligibility requirements m 34 CFR 685.219(c). I am including a link to the regulations should she
Gail =~-~
5 l(b)(6)
From[bl.( l lmailto:
Sent: Friday, June 01, 201~,~,7,~.oTJra~,~vi---~

Hi Ms. Dowling,
fb)(6) I

"'rb"'1rs"'1 ~~csl- -------------

(b)(6)
----------------------------

To; Bl&...!.a!:1;
McLarnon Gail
Cc: l.l.1L...J..oll:
Date: Thursday, August 21, 2014 7:58:52 AM
(b)(5)
.\l:1.ureu1 D( J\\ 1mg, l ·.d. D.

Director
.\lilitan \ff:1.ir~ T e:i.m
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From: Foss, Ian

Hi Maureen,
I'm sorry for the delay. I've drafted a response and 1t 1sin the process of being reviev.,ied. I hope that
we can have the letter sent out soon

To: Mclarnon, Gail; Foss, Ian
I just \\:7.llted 1(1t(Juch li:7.~L-

(Jll this matter a~l(b)(B) linf(mnul nll' th:11 ~he h:i.s rn11 recel\ul
:7.ll\ C()rresp()rnknce reg:i.rdmg this mattn .. \light \(JU be :i.bk t(J kt me krn1\\ the statu~ (Jf I'S.\\
resp()n~e:'
Th:i.nb,
.\l:1.urcu1


(b)(5)
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricc (Jf l1111cJY:tti(i11;u1d ln1pnJ\Tt11c11t
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(b)(5)
Please contact Ian Foss in FSAif you have further questions. Thanks,
G,1il McLarnon
202-210-7048

To: McLarnon, Gail
.\!aurcc11


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)

!)1rcct!ir
( )fricc (Jf "t\cJ11-Puhl1e1·.duc1thJ11and
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iu;/ ,f) ()ff.
Fromfbl(6) lr~b)(6)
Sent: Sunday, June 29, 2:-o~.~--------~
Hi Ms. Dowling!
string from forever ago, in the hopes you have some advice. I'm not sure if you remember,
colleagues at the Department of Education who work in that area.
think there is an Ombudsman for the program. so we will look into that option. as well. I
Best,
j(b)(6) I
0~ Mon. Jun_25, 2012 at 10:36 PM. Kate Voigt 1(bl(5l Fwrote:
H1 Ms. Dowlmg, ~--------~
colleagues, but it is so reassuring to hear that others are on the same page.
Hope all is well!
Best,
On Wed, Jun 20, 2012 at 12:21 PM, Dowling, Maureen <Maureen.Dowling@ed.gov> wrote:
Dearl(5i(6)l
Thar~· 1(lllf patll'!1Ce 11hik l nm~ultul 1111h1111C(1lk:1.gues l!1 thL' l;ukral Stucknt \id ( )ffice
reg:i.rdmg $JL!r mqu1n. 1:(Jl1(1111I1g 1s therL' rL'~[)(!I1SL'
l(l \(Jllr Lluesti(ll1. PkasL' kt me krn111 if l can
liL' of further a~~1q:1.nce.
\II tlw best,
.\!a11rr:r:11

Director
( )ftlcL' ()r i\()[l Publ!C l.duc:i.ti(ll1
( )ftlcL' (Jf lnrn11ath>n and lmpn11·emL"I1l
l .S. Dq)artmL"I1l ()fl '.ducatHm
...J.!Hl
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(202) 7(,(1 7820
maurr:r:n .d( iwlmµIZDr:d.µ<
J\.

other requirements, be employed full~time by a public service organi:..-:ation.The policy staff in
engaged in partisan or reli ious activities. As a full-time employee of an eligible public service
organization, .i\-1s.(b)(B) ·ervice would be considered eligible as long as she meets the rest of the
Gail
From{bl( 5l [mailtoJ(bJ(Bl h
Sent: Friday, June 01, 20~.-~----~r
Hi Ms. Dowling,
customer service individuals seems conclusive, I've even looked through the statutes
l(b)(6) I


----------------------------
b)(6)
I
----------------------------
(b)(6)
I
(b)(6)
From: Foss Ian

To; Dowling Maureen; McLarnon Gail
Cc: l..!1L...J..o.!:
Date: Wednesday, August 20, 2014 4:43:00 PM
H1M,llHeen,
I'm sorry for the delay. I've drafted a response and it is in the process of being reviewed. I hope that
we car1 have lhe leller ':.enl oul soon
Ian

6_l__ ~linf(mnul
I just \\antul t() touch lia~L' on this matter a~ fb_)(_ 11lL'that ~he has rn1t rcccl\ul
0
respcJ11\et
Thanks,
.\l:1.urcu1


(b)(5)
.\l:1.urcu1

!)1rcct!ir
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lo ()ff 1/FiJ'S
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(b)(5)
Gail Mclarnor1
2U2-21'::l-70118

To: Mclarnon, Gail
.\!aurcc11


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)
.\l:1.urcu1

!)1rcct!ir
( )fricc (Jf "t\cJ11-Puhl1C1·.duc1thJn and

l .S. Dq):1.rtmu1l ()fl '.duc:7.tHm
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\\':i.~hmgt()n, DC 21,2112
(.211.2:1
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FromfbJ(6) wb)(6)
Sent: Sunday, June 25", 20 14 1 .zz r 1v1
Hi Ms. Dowling!
string from forever ago, in the hopes you have some advice. rm not sure if you remember,
Best,
fb)(6) I
On Mon, Jun 25, 2012 at 10:36 PM, Kate Voigt 4(b)(Bl Fwrote:
Hi Ms. Dowling,
colleagues, but it is so reassuring to hear that others are on the same page.
Hope all is well!
Best,
On Wed, Jun 20, 2012 at 12:21 PM, Dowling, Maureen <Maureen.Dowling@ed.gov> wrote:
Dear~
Thanks f(>r 1(lllf pat1u1Ce 11hik l nm~ultul 1111h1111C(1lk:1.guesl!1 thL' l;ukral Stucknt \id ( )ffice
reg:i.rdmg $Jllr mqu1n. 1:(Jl1(1111I1g
1s therL' rL'~[)(!I1SL'
l(l \(Jllr Lluesti(ll1. PkasL' kt me krn111 if l can
lK of further a~~1q:1.nce.
.\II tlw best,
\la11rr:r:11
\hurcr:11 Dmd111g, l·.d. D.

Director
( )ftlCL' ()f i\()[l Publ!C l.duc:i.ti(ll1
( )ftlcL' (Jf lnrn11ath>n and lmpn11·emu11
l .S. Dq)artmu1l ()fl '.ducatHm
...J.!Hl
\\·a\h111gtrn1, $(" 2().2112
(202) 7(,() 7820
maurr:r:n .d( iwlmµIZDr:d.µ<
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organization, Ms.l(b)(B) lservice would be considered eligible as long as she meets the rest of the
Gail
From:fbl( 6l tmailtocl(b_)(~61
_____ ~

Hi Ms. Dowling,
j(b)(6) I
associationof immigrationlawyers establishedto promotejustice, advocate for fair
nationalitylaw and practice, and enhance the professionaldevelopmentof its
seeking permanent residencefor close family members, as well as U.S. businesses
continuinglegal education, information,professionalservices,and expertise through

Liaisonand InformationDepartmentworks with liaisoncommittees,the executive
----------------------------
(b)(6)
(b)(6)
(b)(6)
(b)(6)

To; McLarnon Gail:~
Cc: l..!1L...J..o.!:
Date: Wednesday, August 20, 2014 3:55:04 PM
1 iust \\·anted to touch ha~c 011 th1s matter a~fb)(B) l111forrned rnc that ~he has not 1-ccel\Td
any c()rresprn1dc11ce regarding this rnattn . .\light you he ahk to kt me krHJ\\" the statu~ of 1 ·s \ \
respcJ11~et
Th:i.nb,
.\l:1.urcu1


(;ail :i.nd Ian,
(b)(5)
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricc (Jf l1111cJY:tti(i11;u1d ln1pnJ\Tt11e11t
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I
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(b)(5)
G,1il McLarnon
202-210-7048

To: Mclarnon, Gail
.\!aurcc11


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)
.\l:1.urcu1

!)1rcct!ir
( )fricc (Jf "t\cJ11-Puhl1C1·.duc1thJ11and
.\lilitan \ff:1.ir~ T c:i.m
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From: ~bJ(6J t1Il.ill!t.QfbJ(6J

Sent:unday, June 29, 20141 :22 PM
Hi Ms. Dowling!
I hope you·re well and getting to enjoy the summer! I"m writing to follow up on this email
Best
~
On Mon, Jun 25, 2012 at 10:36 PM,l(bl(61 l(b)(61 f wrote:
Hi Ms. Dowling, ~---_, ________ _J
Hope all is well!
Best,
□
Dear~
Thanks for y()ur patience \Yhik I C()multnl \Yith rny C()lkagues 111tlw l·nkral Student .\id ()frice
regarding y(Hlf 1m1u1ry. l·(illcJ\\"ITlgIS there re\p(inse tcJ y(iur c1uesthJ11. Please kt me kncJ\\" 1f I c111
\II tlw best,
.\l:i.urL'Ul
.\l:1.ureu1 D( J\\ 1mg, l ·.d. D.

Director
( )frice (Jf "t\cJ11-Puhl1C1·.duc1thJ11
( )frice (Jf !1111cJYati(i11;u1d ln1pnJ\Tt11e11t
l·.s. Depanrnent ()f l·.ducat1CJ11
...J.!Hl
\\':i.~hmgt()n, DC 21,2112
(202) 260- 7820

Sent: \'<-'ednesday,June 20, 2012 11:38 i\.i\-1
To: Dowling, .i\faureen
Hi Maureen, In order to qualify for public service loan forgiveness, a borrmver must, among
organization, .i\1s.l(b)(6) !service would be considered eligible as long as she meets the rest of the
have further questions about her eligibility. http:/ /www.law.cornell.edu/cfr/text/34/685.219
Gail
Fromfbl( 6l 61
tmailto,(b_l(_
______ ~

Hi Ms. Dowling,
!{b)(6) I


b)(6) I
b)(6)
(b)(6)

To; McLarnon Gail:~
Cc: l..!1L...J..o.!:
Date: Monday, July 21, 2014 2:44:10 PM
1 \Yill go ahead and kt .\!fbl( 6l lk11my that l·S,\ \Yill lx CCJffe~po11d111g

\\·1th hvr regarding th1~
matter . .\light you ha\T a tmic frarne for \\·hen she ~hould e,pect the letter~
.\!aurce11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )frice (Jf "t\cJ11-Puhl1e 1·.duc1thJn and
.\!ilnan· ,\ff;ur~ ·1earn
( )frice (Jf l11ncJYati(i11;u1d ln1pnJ\Tt11ent
l·.s. Depanrnent ()f l·.ducathJ11
•11!1!.\l:i.r~l:i.nd \\Ulllc, S\\
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\1.1hs1nhr /(J ( )// l.!.JJ:.
ih 11·s (Jr ,ii,//rl/l' 11s11;1·111·/li(-r: (d / :/) ( )//.

M,1ureen, FSAwill draft a letter from on this but we are happy to discuss.

(b)(5)
.\l:1.urcu1
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

!)1rcct!ir
•11!1!.\l:i.r~l:i.nd \\Ulllc, S\\
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\1.1hs1 ( )//.

(b)(5)
Please con Lael lar1 Foss ir1 FSA ii you have further quesl1orh. Thanks,
Gail Mclarnon
Acting Senior Director, Policy Coordination,
Developrner1l and Accredilalion Service
Department of Educ1t1on
202 219 7048
gai I.rncl arnon@ed.gov

To: Mclarnon, Gail
.\l:1.urcu1


Sent: 6/30/2014 8 08 AM
To: Mclarnon Gail
(b)(5)
.\!aurcc11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
.\!ilnan· .\ff;ur\ ·1 earn
( )fricc (Jf l1111cJY:tti(i11;u1d ln1pnJ\Tt11c11t
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\\':i.~hmgt()n, DC 21,2112
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I
\1.1hs1 ( )//.
FromfbJ(6J l[~(b)(6J
Sent: Sunday, June 29, : , , , ·"", "'
Hi Ms. Dowling!
Best,
-~
6_1
On Mon, Jun 25, 2012 at 10:36 PM, f~b-1(
__ ~~(b)(6J Iwrote:
Hi Ms. Dowling, ~---------"
Hope all is well!
Best,
Dear l(b)(6) I
Thanks f(ff 1(llll" pat1u1Ce 11hik l nm~ultul 1111h1111C(1lk:1.gues1I1thL' l;ukral Stucknt \id ( )ffice
reg:i.rdmg \(Jllr mqu1n. 1:(Jl1(1111I1g
1s therL" rL'~[)(!I1SL'
l(l \(Jllr L]Uesti(ll1. PkasL' kt me krn111 if l c:i.n
lK of further :1~~1q:1.ncc.
\11thL·best,
,\i:i.urL'Ul

!)1rcct!ir
( )fricc (Jf "t\cJ11-Puhl1C 1·.duc1thJ11
( )fricc (Jf !1111cJY:tti(i11;u1d ln1pnJ\Tt11c11t
l .S. Dq):1.rtmu1l ()fl '.duc:7.tHm
•11!1! .\l:i.r~l:i.nd \\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
(202) 2!,0 7820
/'<JY
Join the ONPE listscrv!
From: .i\kLarnon, Gail
Cc: Foss, Ian; Moran, Pamela; Utz,Jon; Smith, Brian
Hi Maureen, In order to qualify for public service loan foq.,-'1.veness, a borrower must, among
other requirements, be employed full-time by a public service organization, The policy staff in
FSA and OPE believe that the American Immigration Lawyers Association meets the definition
organi;-:ation that provides public services, it is not a business organi;-:ed for profit, nor is it
organi;-:ation, .i\fs.l(b)(6) !service would be considered eligible as long as she meets the rest of the
eligibility requirements 1n 34 CFR 685.219(c). I am including a link to the regulations should she
Gail
FromfbJ(6J I
[mailto:J,,~~1(6~1=~~--~ll

Hi Ms. Dowling,
fb)(6)


(b)(6)
I
----------------------------
----------------------------

To; McLarnon Gail
Cc: Eo&...!.a!J.;
Moran Pamela: !.!.1L...J.Q.o.;
Smith Brian
Date: Wednesday, June 20. 2012 11 :47:23 AM
Th:i.nb S(l much, c;:i.i!, :i.nd ()thcr\ for thL· do:11kd rL"S[)(l!1~c. I \\ill for\\:7.rd this :i.long lo.\!~.
\ '()!gt.

!)1rcct!ir
( )ftlCL' ()r i\()[l Publ!C l.duc:i.ti(ll1
( )ftlCL' ()r lnrnl\a(j()[l and lmpnl\'L'11lL'I1l
-11!1!.\l:i.r~l:i.nd \\Ulllc, S\\
\\-a\h111gtrn1, DC 2().2112
(2112:1 2W--k.211
n i;tmccn .d(n\"1111g(t_( nl.gc J\"

Sent: Wednesday, June 20, 2012 11 :38 AM
Cc: Foss, Ian; Moran, Pamela; Utz, Jon; Smith, Brian
H1M,llHeen, In order to qu,1lify for public service loan forgiveness. ,1 borrower must. ,1mong other
requirements, be employed full time by a public service orgarmat1on The policy staff in FSA and
OPE believe that the American Immigration Lawyers Association meets the definition of public
':.ervice organi,:alior1 in ::YlCFR G85.219(b} of lhe regulations becau':.e il is a µrivale organi,:alion lhal
provides public services, 1t is not a business organized for profit. nor 1sit engaged 1npartisan or
rel1g1ousactiv1t1es As a full time employee of an eligible public service organization, Ms. Voigt's
service would be considered eligible as long as she meets the rest of the eligibility requirements in
31) CFR G85 21'::l(c). I arn including a link lo Lhe regulations should she have lurlher queslior1s aboul
her e I1g1
bi lity http://www.law .cornel I.edu/cfr/text/34/685. 219
I hope this is helpful
G,1il

To: Mclarnon, Gail
.\light you he ahk to assist rnc \\·1th the llll]LllrY hclo\\" regarding \Yhcthvr a :ill] (h:1()rga111;,atl(J11
- till' \rnnic:i.n lmmigratHm l.:1\\~l'rS .\s~(Kiathm -1~ C(HlSlckrul :7.qu:1.lifiul (lrg:7.nl/ath>ll f(>r the
0
Public Scn·JCL' l.(1:1.nl (Hgi\'L"I1L'~~

Pn1grarn~
.\l:1.urcu1
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•11!1! .\l:i.r~l:i.nd \\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
/'<JY
FromJbJ(6J ~(b)(6J
Sent: Friday, June1~---------~
Hi Ms. Dowling,
fb1(6)


and coordinationof agency liaison efforts,conductssubstantivelegal research and
committee and the board of governorsto set and achieve liaisongoals, and works
with governmentagencies to achieve those goals in close coordinationwith other
----------------------------
b)(6) I
(b)(6)
From: Foss Ian

To; Dowling Maureen
Cc: l..!1L...J..o.!:
Date: Wednesday, December 10, 20141:39:00 PM
H1M,llHeen,
I'll be emailing the signed letter to Mfbl(6J !today.
Th;rnks,
Ian

Sent: Monday, November 24, 2014 5:03 PM
To: Foss, Ian
1:7.n,
.\!aurcv11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricv (Jf "t\cJ11-Puhl1e1·.duc1thJ11 and
( )fricv (Jf l1111cJ\":tti(i11
•11!1!.\1:7.r~l:i.nd\\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
:'2112) 2(11J -:-t-;2II
\1.1hs1nhr /(J ( )// l.!.JJ:.
From: Foss, Ian

Sent: Monday, November 24, 2014 8:44 AM
Th;rnks, Maureen I think the email address is fine
(b)(5)
(b)(5)

Sent: Friday, November 21, 2014 4:12 PM
To: Foss, Ian
Dear Ian,
(b)(6)
.\!aurcc11

Director
( )ftlCL' ()r ][1!1()\a(j()[l and lmpnl\'L'11lL'I1l
...J-!Hl.\hrybnd .\n·mic, S\\
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maureen.Jowlino·(t/:ed.v(1\·
_\·11/1yr/1';{'
lo ()ff 1/FiJ'S
/wn· orjr,//oil' 11.rr,11"/!1•1/ir1:·
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From: Foss, Ian

Sent: Friday, November 21, 2014 1 :53 PM
Hi Marueen,
Sorry this took so long WP. h,wP. a f1n,1lize letter that 1srP.ady to bP. sP.nt to Ms Voigt S1ncP.you have
communicated with her, I assume you have her contact information. Could you pass that along so
that we can send direct the letter to her)
Thanks,
Ian

1:7.n,
(b)(5)
.\!aurcv11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricv (Jf "t\cJ11-Puhl1C1·.duc1thJ11 and
( )fricv (Jf l1111cJY:tti(i11 ;u1d ln1pnJ\Tt11c11t
l·.s. Dvpanrncnt ()f l·.ducathJ11
•11!1!.\1:7.r~l:i.nd \\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
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From: Foss, Ian

(b)(5)
(b)(5)

(b)(5)

!)1rect!ir
( )fricc (Jf "t\cJ11-Puhl1e 1·.duc1thJn and
l .S. Dq)artmu1l ()fl '.ducatHm
•11!1!.\lar~land \\Ulllc, S\\
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From: Foss, Ian

111Maureen,
I'm ':.Orry for Lhe delay. I've drafled a response arid il is in lhe µroce':.S of being reviewed. I hope lhal
l.'./P. c;rn have the letter sent out soon
Ian

;u1y ccJrrespcJ11dc1ice regarding this n1attvr . .\light y(HI he ahk t(J kt me kncJ\\' the statu\ (Jfl'S \\
Th:i.nb,
.\!aurcv11


(b)(5)
.\!aurcv11
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
( )fricv (Jf "t\cJ11-Puhl1C1·.duc1thJ11 and
( )fricv (Jf l1111cJ\":tti(i11;u1d ln1pnJ\Tt11c11t
•11!1!.\l:i.r~l:i.nd \\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
:'2112)2(11J -:-t-;2II
\1.1hs1nhr /(J ( )// /.!.JJ:.


(b)(5)
Gail McLarnon
Aeling Senior Direclor, Policy Coordinalior1,
Development ;ind Accreditation Service
Department of [ducat1on
202-219-7048

To: McLarnon, Gail
1!1, Cail.
l [()pc \(JL!r time :7.\\:7.\ 11:1.~ g()rnl.
.\!aurcv11


Sent: 6/30/2014 8:08 AM
To: McLarnon Gail
(b)(5)
.\l:1.urcu1
.\l:1.urcu1 D( J\\ 1mg, l ·.d. D.

Director
•11!1!.\l:i.r~l:i.nd \\Ulllc, S\\
\\':i.~hmgt()n, DC 21,2112
:'2112)2(11J -:-t-;2II
maureen.do'\vlin(r(t/:edy(1\·
\1.1hs1 ( )//.
From: Kate Voigt (~(b)(6J

Sent: Sunday, June 29, 2"'D"l"4~1":ry2ry2•P~M~--~
Hi Ms. Dowling!
string from forever ago, in the hopes you have some advice. rm not sure if you remember,
Best
~Jun.25, 2012 at 10:36 PM, ~bl( 6 1 H(b)(61 I>wrote:

H1 Ms. Dowlmg,
Hope all is well!
Best,
Dear~
Thanks f(>r 1 (lllf pat1u1Ce 11 hik l nm~ultul 1111h 1111 C(1lk:1.gues l!1 thL· l;ukral Stucknt \id ( )ffice
regarding y(Hlf 1m1u1ry. l·(illcJ11·1ngIS there re\p(inse tcJ y(iur ljllCSthJn, Please kt me kncJ11·1f I c1n
lx of further :t\\l\tancc.
\II tlw best,
.\!a11ree11
.\l:1.ureu1 D( J\\ 1mg, l ·.d. D.

Director
( )ftlCL' ()r i\()[l Publ!C l.duc:i.ti(ll1
( )frice (Jf l11ncJY:tti(i11;u1d ln1pnJ\Tt11cnt
l·.s. Depanrncnt ()f l·.ducat1CJ11
---1-!Hl
\\-a\h1ngtrn1, DC 2().2112
(202) 261),7820
maureen.do\vlino·(t/:edy(11·
Hi Maureen, In order to qualify for public service loan forgiveness, a borrmver must, among
organization, .i\-1s.l(b)(6) !service would be considered eligible as long as she meets the rest of the
have further questions about her eligibility. http:/ /www.law.cornell.edu/cfr/text/34/685.219
Gail
Fromfbl( 6l tmailtoj(b)(6J
Sent: Friday, June 01, 20 ""2r1~2~:o~s~A"M~--~

Hi Ms. Dowling,
i{b)(6) I

r(6)
(6)(6)
----------------------------
b)(6)
I
(b)(6)
--~~ca-----------
I
(b)(61
(b)(6)
From: Foss Ian

To; Baker,Jeff
Subject: RE: Voigt
Date: Monday, August 25, 2014 1:45:00 PM
Attachments: PSLF AILA 20140825 pm Foss docx
See attached
From: Baker, Jeff

Sent: Monday, August 25, 2014 1 :01 PM
To: Foss, Ian
Subject: Voigt
Jeff Baker, Director

Policy Liaison and Implementation
Federal Student Aid
Page 4777 of 7666
(bi(51
Page 4778 of 7666
(bi(51

To; FedLoan PSLF
Cc: 011blicservice
Subject: Re: American Immigration Lawyers Association
Date: Wednesday, May 07, 2014 12:12:40 PM
Attachments: AILA - M1ss1on & Goals.pd!
Aillerican Immigration Lawyers Association.zip
Hi Ian, Thanb again for talking with Kim and me today. The discu~sion
really helped!
(b)(5)
Diane

To: puhlicservice@ed.gov
Date: 05/06/2014 10:01 AM
Suhject: Puhlic. American Immigration Lawyers Association
Sent hy: Diane Freundel
(b)(5)
(See attached file: American Immigration Lawyers Association.7ip)
Diane Freundel
Compliance Services
(717)720-1267
fax- (717) 720-3911
dfreunde@pheaa.org
This me,,age contaim privileged and confidential information intended for the ahove addressee, only. If you
receive this me,sage in error please delete or de,troy this me<;<;ageand/or attachments.
The sender of this me<;<;agewill fully cooperate in the civil and criminal prosecution of any individual engaging
in the unauthorized me of this message.
""°"'I lil>II> I ~ I ~ I ~ I Ml2l2lli> ~

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0MB No 1545-0047
black lung
2012
Inspection
I Add1<·ss,I,,,.,q,· 23-7085097
(202)507-7600
( 11¥ IH n,wn, st<0t,• or 1111m11y, """' /IP
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Summary

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OBTAINEDMay
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OF INFORMATION ACT
(Page 6 of 8)
9: I4AI/ 6
9orrower Name: Laura L~nch

s{b)(6)
Borrow...-.S
SECTION 3: CERT/nCAT10N OF CIMPf.OYMENT

.SGBSBction3 ot 1h11
accomp~"Yi•1g Ctrliii~o/ion fw Pubfro
/mtruc/ion3forComp/11/inqErnp/Qyr11t:;(// An authomedofficlsl (.....,Section~) ,:,fthe publicGllrvic!!

. Complete1n1,!¢rm9nly ify-,u ~~ ,;1n~ulhllriiledllfflwl Qf the publiG6erviooorganizationm 1111hlMtile oorrowerielenliliedin Stt~on 1 is/w8g employ@.l
or It (~e
. borromir 1ofwa:1
a ru11,11me
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in Sec11Dn
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.. Typ~or prl~t~:lir'i!I ink. All ~dd~ rr,~~Iii<:wrnplelc:Uif <i~J)ii(;tlbil!.

i:.i11n~tu1~
l'twi\le all requestedinformationlor Ileitis 1. 2, and 3 below. CompletBtt,e em~l<,>Y,:~$
cannotbe pro,:es~edif 1heinfonnationra<JUested In thi~seetionis missing
dolt: rnuMi111:lude
es,rtilie.i.li~n
monlll. day, and year (~M-DD-l'YYYJ,
form
. 11you make ~ny ch~"lles m the lmmm~\tonyou pr<:>\/ide

in th~ section,you mu~I1n1var
ea~he~ar'i!le.
Plea11e return the eom11l~tlldform to th!!-borrownr_ 'r"M U.S. OepMmenlof Educationortlte P.'lLF,ervlce, o'\\llVeo~l~etyou Foradditic>nal informationor
doeu111en1at;on
. forlklrfllwerwh~n tflel'{I ii'; no Authorized Offlclal'.

!1'1$trY~ti-,rn;
0 Checkthis box iFyouare unableto obtaino,:,rt1fie.\l10n
inforrna!lonfor Hems1, 2, and 3 below For 11
from an authonzedoff,clal,for e"-'lmple,beeau$10'\heoro;,anizalion no longerexi,ts. ~rooldeall re~ueslc,d
..m 1, Ii~ the or,ianization·•addra•~from when you worlw(l (lie~. and ron5Lillyour W2.mcordsfor t~e EIN,TOe
Deo~rtmen1w111 VO~ t(oWbm1(
r~<1Ulr'le ~ddi1i11naleviden~ □r youl._9.~alii.D.l!_
tl!)J IQ.t_ment Do n □ t ;ubmil ;u11oanln □ OOCLitller'\S
1. Information about the puhlit: urvit:11 nr911nin1tion1!.twhlth !ht. b0r"16w.:.1 itlw~~ <>mplo~,;I.
Amerl,:-;in Tmmicrr,.t.inn I ""~Ill""~

Public Service Organiza!1 □r1 Name
~:!S!:ociaation
12131· 11101~161o1q1~1
FedN~lly Ass1gMd Employer 10# (EIN)
J.3:31.G. Street HW, S:1Jite- 300, ""~hingt □ n DC 2 □ 0 □ 5
2. Borrower's Employment Sl~lu.__
{•) D;ites of employment.

(MM-DD-YYYY)
S(art l..£.J.._9JL"l.!.I I 2 I O I 1 I 3 I End· 10(31· @1 -1'-1°1\ 1'-1I
(II the borrower is slill employ~, pu1tod~y·s datt)
{bl Borrower's emJ)lovmantstatus at vo1irorgll.nira:1\IM'
IX]Full-Tlme Averagt;,numbs,rof ~QU~p,:,rW@tk. ~

0Part•Tlmit Avsra!J" number of hours per week: ___
For purpose$of eliQibllllylot PSLF. full-time employment isde!in!l-d as.

(A) An annual average orat llalc16t a
~o hou~ per week or. for a contractual or employment perio,:tot at least months, cli"Iavarege of 30 hour,: per
week: or
(BJ Unle~ the qual1fylnf}amploymBntig with two or more employ,ns. 1nenumber of h□ur;i 1neemployer oons1der$full-lime.
(2) V~<;-\1\IOn oy tne employer or ltlclvetaksn for <l condiliori thal is a qualiMnq r1monfor leave under the Family and Medical
Lea\'ti Act of 1993, W U.S.C. 2612(a)(1)aml (31is eouivalelll 10hours IM'H'lfficl in Qual1fy1ng emplovment.
NOTE: A lull-lim~ Amari<-nrp~or Peace Corps volul"IIMr i~ conBid,;,r,;,~ ~ fo,11-timeemp!Q~e for oligibili!y purp11,_,,fQrP-SLF
3 Typl! of PubllG Servk<>Or!Jilniz-!ltion, In aeeordance with the definition In Sec lion~ (ehl'ltk onn),
(a) D
A9ovorn1Mnt organi2ation (mclud1nga Federal. Slat~\ local or Tribal orgenizi;ition.agency orenlity' a J)Ubllcchili'.l""°fumily 5erv1oeagency-or
/bl 0 A non-profi!, WK-e~empt organization under Section 501(Q)(3)of the lnWmal fi.nenun Code:
le) Jg) A 11rivate.non-profitorganliatiori (lh~l ls i"IOIa labar union or a psrtis1mpolitical organlzatim) Iha\ pm~ide,sat lee.i.toni; of 1hefollowi111,1
publie
sar·,ice,a(check all that apply)·
0 Erlltll'!lBncy1ll<lns1gement
□ Mili!ary service.
0 ~1,hlir,~MAiy,
0 Lawenlorcemenl.
D Public i~Mirestlaw ~~rvices.
D E:,rly childhood edi,cation (including licensedOf regulated ctilld care, Hesd S!srl, sn\l St:,te-1\Jndedpre-kindergarten).
0 Public serviC8lormdivldual5 wilh d12ab1llllegand 1hll eldsrly,
D Public haaljh Onclui:lingnufSeS.r"lu~ praciilioners. nurses in a clinical settln{l. arid full-Iima prnfeesi<.>nals
engaged In ha~llh c:,<i,e
Pl<lctitioneroccupalion6 end health '>Llpponoceupatloris. as sLJci11enns are Oe~nedl:ly the Bureau of Labor Sia:ilistica),
lo) Publ1tOlldwoat,cn,
□ Publ10l1t,ra,yservices,
0 C:Hherschool-ba~edservices.
NOT!::<1sto ca1egonea[bJ and (CJ:~or purpo~e~ofths full-11merequirement(Section 3. Hem2.(bl above). .aborrower's Qli3lllylnl) tni'lplayment does not
include lime spi;nt on job du~es tnal ere related 10reli{liouSinsl!uci1on,11\'0rship seiv1ces,or any form nt prns1dyli?ino
.:ISiridicated abov.!:. .:,rls/w~~ sef\ling 1n/ln

I certity lh~l lhe borrower ioen!if1edIn SQCtiOn1 above i~lw/ls employed tit a publk: service orgeni~<"liO~,
AmeriCorp;. or Peace Cor~~ position (m s~cordance wllh the definitionEof lhe3e terms in Section 5) during tl"Kl p,3riorliden1ilie,;iin l(e111 2(a) of this seclicn.
Theresa A. Wat.!r$ Senior OiMCIOr,HR 1mdAdminislralion
[b)(6) tnted) Autllc1ized Oflle1~1·~
Tille
\202 I 507-7600 03' 19· 201~

Authorized Offic1iil'~Sinnatur~ Authori.:11dOffi~1al'~Tele.,hone Tod;iv·s O;i(,;, MM-DD-WYV
(Page 2 of 8)

,,,11 2
AMERICAN
.IMMll~MrION
LAWYERS
ASSOCIATIO:sl
M>rch19, 2014

FedLoan Servicing
P.O. Box 69184
Dear Sir or Madam:


by the Burt;?(I.U
proselyti;:ing.
(emphasisaclded)..
AILA NatlonalOffice
1331GStreet
DC20005
IOI 5077600I Fax:202.783.7853
(Page 3 of 8)

,,,11 3
ot


and more. 2

i111rnii-:rntio11

3
(Page 4 of 8)

,,,11
, . J l"I 4
immigrants' rights organi;;ationsdesigned to increase access to justice for low-income

immigrants and strengthen the capacity of the organi2.ationsserving them. IAN
immigration advocates ~nd organizations by providingfree, easily accessible, and
comprehensive on line I t:.'lourc~sand tools.
• Media Cornmentary:AILAstaff, AILAleadership, and AILAmembers are contacted

commentary on immigration law and policydevelopments because of their expertise in
the field.
• LegalEducation Opf)ortunities: AILAoffers numcrou:.,lcguleducation opportunities and

publications, which are available to the public. AILA'sEducation Department presents
in-person conferencfls1 livewebcasts, live audio and Wi:'bseminars, and OnDemand
AILAis the leading publisher of information and analyses servingthe practicing
Immigrationlawyer, which includes books and resources used by law school1
government agencies1 nonprofit organ'1zations,and attorneys in private practice.
• Pro Dono Programs: AllAprovides the public with pro bono service programs such ns
AILACitizenshipDayand AILA MilitaryAssistance Program. AILACitizenshipDay
provides free or low-cost assistance to eligiblfllegal permanent rflsidents who wi.~hto
apply for U.S. citizenship1 utilizingpartnerships between AILAchapters across the
country and grassroots organizations, AILAMilitaryAssistance Program (MAP)is a
collaborative effort betwsen AILAnnd th@I @galAssistance Offices (LAO)of the United
States militaryJudge Advocate GenP.ral',i; (JAG)Corps that provides knowledgeable pro
bono legal counsel to men and womi:'nof the United States Armed Forces.
AILAis a private organi2ation that prrividesthe above public services; it is not a business
organized for profit, nor is it engaged in partisan or religiousactivities, and thus qualifies as a
publri;:service organization for purposes of PSLF.If you have any questions, please feel free to
Sincerely,
(b)(6)
11eresaA. vvaters
Senior Director, HRand Administration
/\mcric;;inImmigration LawyersAssociation
American ImmigrationCouncil
From: Baker Jeff

To; ~
Subject: KbJ(6) I
Date: Monday, August 25, 2014 1:01 :05 PM
Attachments: PSLF AILA 20140825 Foss-baker-august 25 docx
Jeff Baker, Director

Policy Liaison and Implementation
Federal Student Aid
Page 4788 of 7666
(bi(51
Page 4789 of 7666
(bi(51
loan"
SERVICING
Public Service Loan

Forgiveness (PSLF)
Index
Customer Service
LC
f loan·
SERVICING
PUBLICSERVICELOAN (PSLF)FORGIVENESSINDEX
Topic Index
Table of Contents
How to Use This Document ...................................................................... 8

Document Version Control ..................................................................... 10
PART A-Foundational (Phone) Guidance .............................................. 14
Section A1: L l FLS Only: Public Service Loan Forgiveness (PSLF)

Landing Page .......................................................................................... 15
Definition .............................................................................................................. 15
General Guidelines ................................................................................................. 16
Eligibility Requirements .......................................................................................... 16
Al.1 L Direct Loans Only: PSLFDirect Loan Eligibility ................................................................. 16

Al.2 L l FLSOnly: PSLFConsolidation Loan Eligibility ............................................................ 17
Al.3 L Direct Loans Only: PSLFQualifying Repayment Plans...................................................... 17
Al.4 L Direct Loans Only: PSLFQualifying Payments .................................................................. 19
Al.5 L Direct Loans Only: PSLFQualifying Payments: AmeriCorps ............................................. 20
Al.6 L Direct Loans Only: PSLFQualifying Payments: Peace Corps ............................................ 21
Al.7 L Direct Loans Only: PSLFQualifying Payments: Department of Defense (DOD) ............... 22
Al.8 L Direct Loans Only: PSLFNon-Qualifying Payments Plans ................................................ 22
Al.9 L Direct Loans Only: PSLFNon-Qualifying Payment Statuses ............................................. 23
Al.10 L Direct Loans Only Non-Qualifying Payments: Combined Periods of Service with PSLF.23
Al.11 L Direct Loans Only: How to: Determine Eligibility for PSLF............................................. 24
Al.12 L Direct Loans Only: How to: Navigate the FLSWebsite to Answer Eligibility Questions 24
Counseling ............................................................................................................ 25
Al.13 L Direct Loans Only: How to: Counsel a First Time Caller for PSLF................................... 25

f loan·
SERVICING
Topic Index
Al.14 L l FLSOnly: How to Handle Calls Regarding PSLFApplication ................................... 26

Al.15 L Direct Loans Only: How to: Advise Removal of PSLFPaid Ahead Status ....................... 26
Al.16 L Direct Loans Only How to: Comment PSLFAccounts .................................................... 27
Consolidation......................................................................................................... 29
Al.17 L Direct Loans Only: Consolidating Direct Loans with Qualifying Payments for PSLF...... 29
Al.18 L l FLSOnly: Cautioning Borrowers on PSLFConsolidation ......................................... 29
Al.19 L l FLSOnly: Loss of Borrower Benefits Due to PSLFConsolidation ............................ 30
Al.20 L l FLSOnly How to: Complete the PSLFConsolidation eApplication ......................... 30
Al.21 L l FLSOnly: Federally-Held Loans Not Yet Consolidated ............................................ 31
Payments.............................................................................................................. 32
Al.22 L Direct Loans Only How to: View PSLFPayment Count on the FLSWebsite .................. 32
Al.23 L Direct Loans Only How to: Review Payment Screens l(bl(6l 1.....................................
.33
Al.24 L Direct Loans Only How to: Review Number of Qualifying Payments when Borrower's
l(bl(6l
Loans are on COMPASSsM 1 .................................................................................................... 35
Al.25 L Direct Loans Only: Payment History Task (PSTRK) Created ......................................... .35
Al.26 L Direct Loans Only How to: Handle Borrower Call about Why Payment Is or Isn't
Approved for PSLF........................................................................................................................... 36
Al.27 L Direct Loans Only How to: Review the Payment History Screen for PSLF.................... 37
Al.28 L Direct Loans Only How to: Review the Repayment Schedule History Screen .............. 38
Al.29 L Direct Loans Only Super Screen How to: Review the Billing History Screen ................. 40
Al.30 L Direct Loans Only: Call Regarding Payments While on In-School Deferment ............... 41
EscalatedCalls ...................................................................................................... 42
Al.31 L Direct Loans Only When to: Transfer a Call to PSLFSplit .............................................. 42
Al.32 L Direct Loans Only When to: Escalate a Call to PSLFEscalated Split.. ........................... .43

f loan·
SERVICING
Topic Index
Al.33 L Direct Loans Only How to: Handle Expedited PSLFRequests When an Expedited
Request Already Exists on the Borrower's Account ........................................................................ 43
Al.34 L Direct Loans Only How to: Handle Additional PSLFReview Requests .......................... 44
Submitting Review ................................................................................................. 44
Al.35 L Direct Loans Only When to: Submit the RVWPS ARC ................................................... 44
Al.36 L Direct Loans Only When to: Submit the REVCFARC..................................................... 45
Al.37 L Direct Loans Only When to: Submit the PSREVARC.................................................... .46
Al.38 L Direct Loans Only When to: Submit the PSNPRARC ................................................... .46
Al.39 L Direct Loans Only PSCBK:PSLFCall Back Request ........................................................ 47
Opt-Out ................................................................................................................ 47
Al.40 L Direct Loans Only: Call Regarding Opting Out of PSLF.................................................. 47
Al.41 L Direct Loans Only: Borrower Chooses to Opt-out of PSLF............................................ 48
Non-Core Information ............................................................................................ 49
Al.42 L Direct Loans Only: PSLFEmail Campaign ...................................................................... 49
Al.43 L Direct Loans Only: PSLFAnnual ECFRecertification Email Campaign ........................... 50
Al.44 L Direct Loans Only: Super Screen Disposition Codes ..................................................... 50
Al.45 L Direct Loans Only: Calls Regarding Natural Disasters ................................................... 50
Section A2: L Direct Loans Only: Public Service Loan Forgiveness (PSLF)
Employment Landing Page ..................................................................... 52
ECF...................................................................................................................... 52
A2.1 L Direct Loans Only: Refer the Borrower to the FLSWebsite for an ECF........................... 52
A2.2 L Direct Loans Only How to: Navigate the FLSWebsite to Answer Employment
Certification Form Questions .......................................................................................................... 52
A2.3 L Direct Loans Only How to: Manually Send the ECFto FLSBorrowers ............................ 53

f loan"
SERVICING
Topic Index
A2A L Direct Loans Only How to: Manually Send the ECFto Non-FLS Borrowers .................... 53
A2.5 L Direct Loans Only: PSLFECF Update ............................................................................... 54
A2.6 L Direct Loans Only: Advising the Borrower How to Complete the ECF............................ 54
A2.7 L Direct Loans Only: How Often a Borrower Can Submit the ECF..................................... 55
A2.8 L Direct Loans Only: Determine if the ECFWas Received ................................................. 56
A2.9 L Direct Loans Escalated Situation Only How to: Image an ECF........................................ 56
A2.10 L Direct Loans Only COMPASS How to: Review ECFon ITL2U ....................................... 57
511
A2.11 L Direct Loans Only: ECFin Approved (A) Status ............................................................. 57
A2.12 L Direct Loans Only: ECFin Denied (D) Status ................................................................. 58
A2.13 L Direct Loans Only: ECFin Conditionally Approved (C) Status ....................................... 58
A2.14 L Direct Loans Only: ECFin Hold (H) Status ..................................................................... 58
A2.15 L Direct Loans Only: ECFin Review (R) Status ................................................................. 59
A2.16 L Direct Loans Only How to: Handle Call Received from an Employer to Complete ECF59
Employer Qualifications .......................................................................................... 60
A2.17 L Direct Loans Only: PSLFQualifying Employment .......................................................... 60
A2.18 L Direct Loans Only PSLFQualifying Employment: Government Organization ............... 60
A2.19 L Direct Loans Only PSLFQualifying Employment: Non-profit Tax-Exempt Organization

Under 501(c)(3) of the Internal Revenue Code ............................................................................... 61
A2.20 L Direct Loans Only PSLFQualifying Employment: Private, Not-for-Profit Organization 61
A2.21 L Direct Loans Only PSLFQualifying Employment: Supporting Documentation ............. 62
A2.22 L Direct Loans Only How to: Determine if the Employer Qualifies .................................. 63
A2.23 L Direct Loans Only How to: Review Directories for Federal, State, Local or Tribal
Government Organization, Agency, or Entity ................................................................................. 64
A2.24 L Direct Loans Only How to: Review Directories for Non-Profit 501(c)(3) Organizations65

f loan"
SERVICING
Topic Index
A2.25 L Direct Loans Only: Employer Not found or Discrepancy found When Reviewing
Directories for Non-Profit 501(c)(3) Organizations ......................................................................... 66
A2.26 L Direct Loans Only How to: Review Directories for Private, Non-Profit Organizations ..66
A2.27 L Direct Loans Only How to: Handle Requests to Override Judgment of Denied Employer
........................................................................................................................................................ ~
L Direct Loans Only How to: Handle Employer Not Located or Not Qualified ................ 67
A2.28
A2.29 L Direct Loans Only: Call Regarding Ineligible Organization ............................................ 67
PART B - L FLS Only: PSLF Employment Certification Processing

Procedure ................................................................................................ 69
Summary ................................................................................................. 69
Section B1: Pre-Processing .................................................................... 70
B1.1 Retrieve ECF in FileNet. ............................................................................... 70

Bl.la Multiple ECFs........................................................................................................................ 70
Bl.lb Determine 0MB Approval .................................................................................................... 72
Bl.le Draft Application for Forgiveness .......................................................................................... 72
B1.2 Review Demographics ................................................................................. 72

Bl.2a FLSBorrower Demographics ................................................................................................. 72
Bl.2b Non-FLS Borrower Demographics ......................................................................................... 73
Bl.2c Non-FLS Borrower Missing Demographics ............................................................................ 73
Bl.2d Script: Missing Demographics ............................................................................................... 74
B1.3 Review NSLDS............................................................................................ 75

Section B2: Processing the ECF(s) ......................................................... 76
B2.1 Review the ECF.............................................................................................. 76

B2.la Sections 1 and 2 .................................................................................................................... 76
B2.lb Sections 3 and 4 .................................................................................................................... 77
B2.lc Box 15 .................................................................................................................................... 80
B2.ld Additional Fields ................................................................................................................... 81
B2.le Unable to Obtain Certification .............................................................................................. 82
B2.lf Missing/Conflicting Information ............................................................................................ 83
B2.lg Script: Missing ECFInformation ............................................................................................ 85
B2.lh PSLFCallback Macro ............................................................................................................. 86

f loan"
SERVICING
Topic Index
82.li Requests to Override Judgment of a Denied Employer ......................................................... 87

B2.lj Attached Certification ............................................................................................................ 88
B2. lk ECFRetraction ....................................................................................................................... 89
B2.11 Escalated Situation: ECFWas Denied ..................................................................................... 89
B2.lm Escalated Situation: Self-Certified ........................................................................................ 89
B2.2 Review the Employer Website/Directory ........................................................... 90

B2.2a Employer Match Not Found .................................................................................................. 93
B2.2b Government Organizations ................................................................................................... 94
B2.2c Non-Profit 501(c)(3) Organizations ....................................................................................... 96
B2.2d Private, Non-Profit Organizations Providing Public Services ................................................ 96
B2.2e Escalate Non-Approved (Not Listed) Employers ................................................................... 97
B2.3 ECF Requires Further Review .......................................................................... 98

B2.4 Review PSECFProcessing Macro ..................................................................... 99
B2.5 Sending a Manual Denial Letter .................................................................. 104
B2.6 Process the RVECFARC............................................................................. 107
B2.7 Commenting on the PSLFScreen e'.::J.................................. 107
B2.8 Archive Image .......................................................................................... 108
B2.8a FileNet Imaging ................................................................................................................... 108
B2.8b PSCOM Document .............................................................................................................. 108
Acronyms .............................................................................................. 110

Related Documents .............................................................................. 111
Related Letters ..................................................................................... 112
Related Forms ....................................................................................... 112
Approval Letters .................................................................................................. 112

Denial Letters ...................................................................................................... 112
Action Required Letters ........................................................................................ 113
Additional Letters/Forms ....................................................................................... 114
Related Technologies/Reports ............................................................. 116

f loan·SERVICING
Topic Index
Screens ............................................................................................................... 116

Work Queues/Action Request Codes (ARCs)........................................................... 116
Scripts ................................................................................................................ 117
PageCenter Reports ............................................................................................. 117
SAS Jobs - N/A .................................................................................................... 118
Other .................................................................................................................. 118
Appendix A - Loan Abbreviations ......................................................... 119
A.1 FFELPand Direct Loan Abbreviations Chart .................................................... 119

Resources/Authority ............................................................................. 120

f loan"
SERVICING
Topic Index
How to Use This Document

This document aims to create a comprehensive reference collection of resources relating to an overarching
topic. It contains foundational guidance covered during a phone call (i.e. eligibility requirements) and
processing procedures, which is divided into two parts detailed below.
PARTA contains the phone and foundational guidance that is often found in knowledge repository articles.
The structure of PARTA is similar to landing pages found in Knowledge Center (KC). For example, new
sections such as Section Al indicate a landing page topic. The standalone articles contained within the topic's
landing page are notated as decimal subsections such as Al.1 or Al.2 followed by their title. See the
comparison below.
Topic Landing Page _____ __. V✓
1 ID.:~~-·-':-""".:::;J-lf""':": I
Section Al. Topic landing
Pag12
Definition and
General Guidelines ····n,. undo con,.,n, gu,donc• for All loon Prog,,.,.,, •···
Definition
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Sub-topic Heading
~~
Authenticated Caller Later Determined Unauthorized I
Standalone Articles
----+
Al 1: Topic SA
Document Version Control ----+ .r=_··__ ·._.;·_,'._,_;,_,_.,_.. _,_,_,._._, _=·,_,_· •_··_.,_.,_,~
Proprietary & Conf1dent1al Page I 8
PHeaa
f loan"
SERVICING
Topic Index
PART B contains processing procedures relating to this document's overarching topic. If multiple procedural
manuals are to be included in this index document, each new procedure manual will begin a new PART, such
PART C: ABC Procedures.
Reference materials such as related documents, letters, and technologies, along with appendixes are located
at the bottom of the document.
Note to Compliance, Writers, and Subject Matter Experts: This document is not intended for Phone
representative use. PARTA phone and foundational content will be made available in Knowledge Center as
articles for phone representatives. However, both Parts will remain in this index document for the processor
reference and use. All edits to content, whether article or procedural, must be made using this document.
Once edits to this document have been Compliance approved knowledge repositories will be updated
accordingly.
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VERSION PURPOSE/CHANGE AUTHOR/ REVIEWER DATE
Initial publication of PSLFIndex per incident 29045584224 E. Thomas/ T. 08.03.16

(PSLFIndex Project Incident). Changes specific to content: Galloway/ B.
Wagner
• General Guidelines: PSLFReminder- When speaking to a
borrower, do not use the term/phrase 'enrolling in PSLF'
• Section Al.34 (When to Submit the RVWPS ARC):
0 Note added - If a blank task is created in the
RVWPSqueue, close the task as no adjustment
and submit a QAOOO
0 When the payment tracking task is complete, a
PSPMC ARC should be populated to comment the
closed task
• Section A2.3 (How to Manually Send the ECFto FLS
Borrowers): Note added -When sending a manual letter
to a borrower, the borrower's account number should be
1.0 used, not the SSN
• Section A2.8 (Determine if the ECFWas Received): Note
added - Super Screen has an alert to indicate that a PSLF
borrower submitted an ECFand has an approved ECFon
file
• Section B2.4 (Review PSECFProcessing Macro): New
section - replaces the former 'No Eligible Loans Macro'
• Section B2.lh (PSLFCallback Macro): New Launch Pad
Tool - replaces the former PSLFOutbound Tracking
Spreadsheet
Compliance Approved K. Myers 12.19.16
Published by Communications. V. Edwards 12.21.16
Date All Changes for this Version are Effective for Staff. V. Edwards 12.21.16
Part A Published in KC by Migration Team T. Galloway 12.27.16
Date All Changes for this Version are Effective for Staff. T. Galloway 12.28.16
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Fast Track Update: Incident 29045584563 (G307P E. Thomas 01.03.17

Communication) -
• Section Al.25 (How to: Handle Borrower Call about
Why Payment Is or Isn't Approved for PSLF): Guidance
added for when borrower requests payment
1.1 information in writing
Compliance Approved K. Myers 01.03.17
Published in KC by Migration Team T. Galloway 01.05.17
Fast Track Update: Incident 29045584740 (PSLF ECF E. Thomas 02.14.17
Retraction) -
• Section 82.lK (ECF Retraction): New, contains

guidance for when an approved ECF needs changed to
a denied status
Incident 29045584753 (PSLF Due Date vs. Effective Date &
Estimated Eligibility) -
• Section Al Definitions: Added definition for estimated

eligibility date
• Section Al.4 (PSLF Qualifying Payments): Added

guidance regarding required payments during periods
of qualified employment
1.2 • Section Al.21 (How to View PSLFPayment Count on
FLSWebsite): Added If/Then guidance for when a
borrower views their PSLFpayment count on line
Incident 47199054449 (RVWPS)-
• Section Al.32 (How to Handle Expedited PSLF

Requests When an Expedited Request Already Exists
on the Borrower's Account): Clarified guidance to
state that ECFsshould be sent to the FLS PSLF
Supervisor Review mailbox
Compliance review complete, no further comment K. Myers 02.15.17

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Fast Track Update: Incident 47199054584 (PSLFGraduated E. Thomas 03.08.17

Repayment Plan)-
• Section Al.3: PSLFQualifying Repayment Plans-

Relocated guidance regarding Graduated Repayment
plans from Section Al.8: PSLFNon-Qualifying
Repayment Plans to clarify that this plan is eligible
Incident 47199054587 (PSLFFAQ)-
• Section 82.4: Review PSECFProcessing Macro -

Clarified guidance regarding middle initials,
employment time period, and complete name of the
employer
Incident 47199054596 (Phones-Transfer to Specialty Split

Update to Articles) -
• Sections Al.30: When to: Transfer a Call to PSLFSplit

1.3
and Al.13: How to: Counsel a First Time Caller for PSLF
-Added note indicating that if the rep is trained on
the specialty split for PSLF,no transfer is necessary
Incident 47199054663 (PSLF- Organization Address) -
• Sections A2.6: Advising the Borrower How to

Complete the ECF, B2.lb: Sections 3 and 4, B2.lf:
Missing/Conflicting Information, B2.2b: Government
Organizations, B2.4: Review PSECFProcessing Macro,
and B2.2e: Escalate Non-Approved Employers-
Guidance added regarding acceptable partial
addresses
Compliance review complete, no additional comments K. Myers 03.13.17

Published by Communications J. Zook 03.16.17
Date All Changes for this Version are Effective for Staff. J. Zook 03.22.17
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FASTTRACK Update per incident 47199054730: PSLF- T. Galloway/ B. 03.23.17-

Forgiveness Application Wagner 03.27.17
• Section Al.14: FLSOnly: How to Handle Calls

Regarding PSLFApplication -Added
• Section Bl.le: Draft Application for Forgiveness -
1.4 Added
Staff Update: Updated phone call and processing guidance to

include draft PSLFapplication guidance.
Compliance review complete, no further comment K. Myers 03.28.17
Published by Communications V. Edwards 03.29.17
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PART A-Foundational (Phone) Guidance
PART A of this document contains background, eligibility, and other foundational (phone) guidance for the
Public Service Loan Forgiveness (PSLF)to assist with answering the PSLF-related phone calls and processing.
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Section A1: L l FLS Only: Public Service Loan Forgiveness

(PSLF) Landing Page
I KC ,□r)(6) I I
Definition
• Public Service Loan Forgiveness (PSLF) Program: Cancels the remaining balance of a borrower's Direct
Loans after working full time at one or more qualifying public service employers for at least 10 years,
while making 120 qualifying monthly payments after October 1, 2007.
o Established to encourage individuals to enter and continue in full-time employment in lower-
paying but vitally important public service jobs.
• Employment Certification Form (ECF): A form that can be submitted periodically to help determine if
the borrower is on the right track while working towards meeting the PSLFeligibility requirements
• Consolidation: Issuing a loan or loans to replace a group of existing internal and/or external loans.
• Segal Award: Post-service benefit received by individuals who complete terms of national service in
approved AmeriCorps programs. Used to pay educational costs at eligible post-secondary educational
institutions, including qualified student loans.
• Transition Award: An amount paid to Peace Corps volunteers upon completion of two years of service.
Award amount is subject to change.
• PSLFSplit: A specific split in which calls are routed to if the borrower is participating in PSLFor if they
call a specific number.
• Full-time employment: Working in one or more jobs for the greater of:
o An annual average of at least 30 hours per week (or for a contractual or employment period of
at least 8 months, an average of 30 hours per week); OR
o The number of hours the employer considers full-time, unless the qualifying employment is
with more than one employer
Note: This includes vacation, leave time, or any leave taken under the Family Medical Leave
act of 1993.
o If an employer is 501(c)(3) or a not-for-profit organization, any hours spent on religious
instruction, worship services, or proselytizing does not qualify for PSLF.
• Estimated Eligibility Date: The date on which FLSestimates the borrower will make their final
qualifying payment and become eligible to submit their application for forgiveness of the loan.
o This is based on the assumption that the borrower will continue to work full-time for a PSLF
qualifying employer until the time they receive loan forgiveness, while continuing to make on-
time, qualifying payments every month until the time they apply for loan forgiveness.
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General Guidelines
• The borrower will need to complete an Employment Certification Form (ECF)on paper
o If certain information on the form is missing, this can be obtained by calling the borrower or
the employer
■ The ElN can be supplied by either the borrower or the employer.
■ Employment status, hours, dates, or title of authorized official can only be supplied by the
employer. The borrower cannot provide this information.
• The time frame from when we receive ECFuntil loans are transferred is 30-60 days, unless the
borrower has received a TEACH Grant/Loan. The borrower will then be transferred over when all the
TEACH Grants/Loans are transferred.
• According to the Internal Revenue Service (I RS),student loan amounts forgiven under PSLFare NOT
considered income for tax purposes.
o For more information, the borrower should check with the IRSor his/her tax advisor.
Note: When speaking with a borrower, do not use the term or phrase 'enrolling in PSLF.' By
submitting an ECF,the borrower is participating in employment and payment tracking for PSLF.
• Use proper format when entering information into COMPASS'M.
o Enter a space after a colon.
• Correct Format: BLOOMSBURGUNIVERSITY:OFFICEOF FINANCIAL AID
• Incorrect Format: BLOOMSBURGUNIVERSITY:OFFICE
OF FINANCIALAID
o Ensure there is no space before the first letter/number of data in a field.
■ Correct: NAME MATTHEW
■ Incorrect: NAME MATTHEW
Eligibility Requirements
A1 .1 L Direct
l/b)(6)
Loans Onlr PSLF Direct Loan Eligibility
I KCID:
Only Direct Loans are eligible for PSLF.

Loan Type Balance Requirement
L Federal Direct Loans (Direct Subsidized Loans)

Outstanding balance
L Federal Direct Unsubsidized Loans (including TEACH Grants greater than $25.00
that were converted to Direct Unsubsidized Loans))
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L Federal Direct PLUS Loans (Parent or Student)

L Federal Direct Consolidation Loans (Including Special Direct
Consolidation Loans & Spousal Consolidation)
Note: There are no disbursement date restrictions.
Note: Defaulted Direct Loans are not eligible for PSLF.A defaulted loan may become eligible if the
borrower consolidates or rehabilitates the loan and then begins making qualifying payments.
A1.2 L l FLS Only: PSLF Consolidation Loan Eligibility

I KC1ofl( 6l
I
Other federal student loans may become eligible if they are consolidated into a Direct Consolidation
Loan. See the table below for types that may be consolidated into the Direct Loan Program:
Loan Type Specific Requirements Balance Requirement
l Federal Family Education Loan (FFEL)

Program loans:
• Subsidized Federal Stafford Loans

• Unsubsidized Federal Stafford Loans
N/A
• Federal PLUS Loans (parents and
graduate or professional students) Outstanding balance
greater than $25.00
• FFELConsolidation Loans [excluding
Joint (spousal) Consolidation Loans]
Must also consolidate

l Federal Perkins Loans
at least one FFEL
Program Loan or Direct
Certain Health Professions and Nursing Loans
Loan
Note: Only payments made on the Direct Consolidation Loan will count toward the required 120
qualifying payments. Any payments made prior to consolidation will not count.
A1 .3 L Direct Loans Only: PSLF Qualifying Repayment Plans

I KC,o,rb)(6) I
• A qualifying payment is made under one of the following repayment plans:
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o Income-Based Repayment (IBR)

o Income-Contingent Repayment (ICR)
o Pay As You Earn (PAYE)
o Revised Pay As You Earn (REPAVE)
Note: For additional guidance on IDR loan eligibility, see the FLSOnly: IDR Plans
Eligibility Requirements in the IDR Index.
o Standard Repayment Plan, based on a 10-year repayment term
• For a Standard Repayment Plan to qualify, the total repayment term has to be
less than or equal to 120 months for the life of the borrower's loans.
o Graduated Repayment Schedules: start out lower and then gradually increase,
generally every two years.
• Payments made during the beginning portion of the repayment period would
not qualify.
■ Conversely, payments made during the later portion of the repayment period
may equal or exceed the payment amount that would be required under a 10-
Year Standard Repayment Plan. In return, these payments would count for
PSLF.
If Then Example
The borrower already The number of months Borrower was on I BR, made
made payments and the borrower has payments for 36 months, and now
wants to change already made wants to change to a Standard
his/her repayment payments must be Repayment Plan. The borrower
schedule to a deducted from 120 must receive a standard payment
Standard Repayment months. amount for a term of 84 months or
Plan and still qualify, less. If the borrower received a
standard payment amount for a
term greater than 84 months, the
borrower's payments on the
Standard Repayment Plan would
not qualify because the total term
would be beyond 120 months.
o Note: IDR Schedules
• IDR payment amounts of $0 count towards the required 120 payments.
• The remaining loan debt is forgiven after the borrower meets the program
requirements for 120 months.
o Any other Direct Loan Program repayment plan
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• Payments must be at least equal to the monthly payment amount the borrower
is required to pay under Standard Repayment based on a 10-year repayment
term.
Note: Although IBR/ICR/PAYE/REPAYEschedules are disclosed for terms greater than 120
months, payments made under these repayment plans are eligible for PSLF.
• As long as the borrower makes qualifying payments under any of the qualifying repayment
plans, the remaining loan debt will be forgiven after he/she has met the program
requirements for 120 months.
A1 .4 L Direct Loans Only: PSLF Qualifying Payments

i KC ID: rb)(6) I
The borrower must make 120 payments (consecutive or non-consecutive) during periods of qualified
employment.
• The effective date of a qualifying payment must be within the approved employment date
window (certified by an ECF).
o It is acceptable for the due date to fall outside the employment dates.
• See the examples below:
Qualifying Payment Non-Qualifying Payment
Bill Due Date: 01/07/2016 Bill Due Date: 01/15/2016
Payment Date: 01/15/2016 Payment Date: 01/07/2016
Approved ECFCertification Dates: Approved ECFCertification Dates: 01/10/2016

Ol/10/2016-12/31/2016 -12/31/2016
• See the chart below for acceptable payment amounts:
Payment Details Example
On-Time, Full • Satisfy the full current, monthly • The borrower was billed a
Installment Amount payment amount. $50 installment amount for
the 12/15/11 due date.
• Received no earlier than 30 days prior
to the due date and no later than 15 • Payment(s) totaling $50.00
days after the due date. must be received on/after
11/15/11 and no later than
12/30/11.
Partial Payment • Partial payment total is equal to or • The borrower was billed a
greater than the full monthly payment $SO installment amount for
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amount. the 12/15/11 due date.

• Full installment amount is received no • The borrower pays $10.00
earlier than 30 days prior to the due on 12/05/11 and $40.00 on
date and no later than 15 days after 12/10/11.
the due date.
Pre-Payment (Paid • Greater than one full monthly payment • The borrower was billed a
Ahead) amount $50 installment amount for
the 12/15/11 due date.
• Counts as one, on-time payment .
0 If the borrower is paid ahead and • The borrower pays $150.00
continues to make payments, on 12/20/11
each additional payment may 0 This payment will only
qualify as no more than one count as one
qualifying payment towards PSLF, qualifying payment
regardless of the amount paid
Lump Sum Payment Determined by the lesser of: • The borrower's ECFperiod is
(AmeriCorps, Peace certified from 12/15/2010 to
Corps, and DOD only)
• The amount of the lump sum payment
12/15/2011 and was on a
divided by the monthly payment
corresponding National
amount the borrower was due under
Community Service
one of the qualifying repayment plans,
Forbearance for the same
OR
dates.
• Twelve Payments .
• Borrower was on IBR
beginning 12/15/2010 for
$350.
• AmeriCorps lump sum
payment is submitted for
$4,500 on 1/15/2012.
0 This payment will only
qualify as 12 monthly
payments.
$4,500/$350=12.86
Note: Borrowers qualifying for PSLFshould be advised to sign up for Direct Debit to ensure each
monthly installment is paid on time.
A1 .5 L Direct Loans Only: PSLF Qualifying Payments: AmeriCorps

I KC ,0,1,01(6) I
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AmeriCorps volunteers or borrowers who do not make qualifying payments during his/her service
period due to deferment, forbearance, etc., may receive credit for making a limited number of
qualifying payments if a lump sum payment is made.
• To be considered for PSLFqualifying payments, the lump sum payment must be received no
later than 7 years after the borrower's AmeriCorps service.
o Lump sum payments cannot be credited to the account until an approved ECF
(Employment Certification Form) is on file for AmeriCorps.
o Credit can be given for lump sum payments received from the first Segal Award. The
borrower can make multiple lump sum payments as long as they are from his/her first
Segal Award.
• A maximum of 12 qualifying payments from the first Segal Award may be credited for each
borrower.
o If a borrower serves more than one period with AmeriCorps, and receives another
Segal Award, they cannot receive credit from a subsequent Segal Award.
o Segal Awards are paid by the National Service Trust.
• Single monthly payments (including AmeriCorps) count as PSLFqualifying monthly payments,

provided they satisfy requirements:
o The borrower is not on a deferment or forbearance
o The correct payment amount/payment plan is used
A1 .6 L Direct Loans Only: PSLF Qualifying Payments: Peace Corps

I KCID,f'1(6) h
Peace Corps volunteers or borrowers who do not make qualifying payments during his/her service
period due to deferment, forbearance, etc., may receive credit for making a limited number of
qualifying payments if a lump sum payment is made.
• To be considered for PSLFqualifying payments, the lump sum payment must be received no
later than 6 months after the borrower leaves the Peace Corps.
o Lump sum payments cannot be credited to the account until an approved ECF
(Employment Certification Form) is on file for Peace Corps.
o Credit can be given for lump sum payments received from the term of service. The
borrower can make multiple lump sum payments (all received within 6 months) as long
as they are from his/her first term of service
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• A maximum of 12 qualifying payments from the first transition lump sum payment may be
credited for each borrower.
o If a borrower serves more than one period with the Peace Corps, and receives another
transition award, they cannot receive credit from that subsequent term of service.
o Only the maximum transition award amount of $7,425.00 ($8,775.00 for volunteers
starting service after October 1, 2014) should be considered.
Note: This award amount is subject to change. A periodic review will be

conducted to verify the correct award amount.
o Transition payments will come directly from the borrower
A1.7 L Direct Loans Only: PSLF Qualifying Payments: Department of Defense

(DOD)
I KC 10,!(b)(B)
Borrowers participating in a student loan repayment program administered by the Department of

Defense (DOD) who do not make qualifying payments during his/her service period due to deferment,
forbearance, etc., may receive credit for making a limited number of qualifying payments if a lump
sum payment is made.
• To be considered for PSLFqualifying payments, the DOD payment must be received on or after
July 1, 2016.
o Payments come directly from the DOD and are made on behalf of the borrower
• A maximum of 12 qualifying payments may be credited for each DOD payment received.
• The borrower may be on the DOD Student Loan Repayment Program Forbearance during this
time.
o The borrower would need to complete a Mandatory Forbearance Request.
A1 .8 L Direct Loans Only: PSLF Non-Qualifying Payments Plans

I KC 10,1(0)(6) I
The following repayment plans are not eligible for PSLF:
• Extended term.
• Standard (level) plan that is greater than 10 years (Example: Consolidation terms greater than
10 years).
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• Any other repayment plan where the monthly installment is less than the Standard Repayment
Plan based on a 10-year repayment term.
A1 .9 L Direct Loans Only: PSLF Non-Qualifying Payment Statuses

~(b)(6) I
Payments made during the following statuses do not qualify as PSLFpayments:
• In-School
• Grace
• Deferment
• Forbearance
o Note: There are situations where a payment can be made during in-school, grace,
deferment, or forbearance and still qualify.
o For example, the borrower made a payment during one of these statuses to satisfy the
bill due immediately following a suspended status, or the borrower made a payment
during a deferment/forbearance to satisfy the bill due immediately prior to the
deferment/forbea ranee.
• Suspended Activity
• Bankruptcy
• Default
Note: This includes payments made as part of a rehabilitation agreement on a defaulted loan.
Default status means greater than 270 days delinquent.
A1.10 L Direct Loans Only Non-Qualifying Payments: Combined Periods of

Service with PSLF
I KC ID: tb)(6)
~-----------~
The same period of service may not be used for PSLFand:
• Teacher Loan Forgiveness (TLF).
Note: If a borrower has been approved for TLF, and TLF payments have been applied to the
account, the borrower cannot have TLF payments refunded because he/she wants to
participate in PSLF.
• Public Service in Areas of National Need.
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• Civil Legal Attorney Assistance Student Loan Repayment Programs.
A1.1f
I KC ID,
(b)(6)
L Direct l
Lo»ns Only: How to: Determine Eligibility for PSLF
See the table below for guidance on determining the borrower's loan eligibility for PSLF.
If Then
he borrower's loans are currently serviced .terify the borrower has at least one Direct Loan
by Fed loan Servicing pn COM PASS'".
• Review the COMPASS'M Navigation
Training Guide in Content Connection for
assistance.
1) Review NSLDSto verify the borrower has a
Direct Loan. Refer to the KCArticle How to:
Access the National Student Loan Data
System (NSLDS)
No Direct Loans exist on COMPASS'M 2) Ask the borrower for the following:
• Name
• SSN
• Date of Birth
The borrower has at least one Direct Loan He/she can participate in the PSLFProgram.
!with an outstanding balance greater than
$25.00
he borrower does not have a Direct Loan he borrower is not eligible for the PSLFProgram.
A1.12 L Direct Loans Only: How to: Navigate the FLS Website to Answer
Eligibility Questions
To assist borrowers with PSLFquestions, direct the borrower to our website, myfedloan.org.
Borrowers can review the Eligibility Requirements for PSLF.
1) Locate these requirements from the bottom of the home page by accessing 'Public Service Loan
Forgiveness' under 'Special Programs'
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Counseling
A1.13 L Direct Loans Only: How to: Counsel a First Time Caller for PSLF
I KC ,oJb1(6) I
If the borrower calls for the first time regarding general information on the PSLFProgram, follow the
steps below:
1) Explain the eligibility requirements.
2) Encourage the borrower to periodically complete ECFswhile making the 120 required payments
and/or changing employment.
3) Encourage the borrower to record supporting evidence of his/her employment.
4) If the borrower's loans are with another servicer, advise the borrower that once a valid ECFis
received, verified, and approved, we will work with his/her current servicer(s) to transfer only
his/her Federally-held loans to FedLoan Servicing.
5) If the loans are held with FedLoan Servicing, see Counseling Direct Loans with Qualifying Payments
for PSLF.
Note: Not all information listed will need to be provided on every call.
Note: If you receive a call intended for a specialty split, and you are trained on the specialty split, no
transfer is necessary. You should continue with the call, answering the specialty split questions.
If Calling for: Then Advise of:
• Status of ECF
• If FLSborrower:
ECFstatus 0 Review to ensure he/she is on an eligible

repayment plan.
• See Direct Loans Only COMPASS'MHow to:
Review ECFonfbl(Bl
I
Payment requirements • Payment requirements
• Eligible loans
Employment eligibility • Type of organization that qualifies for PSLF

• See FLSOnly Employer Qualifications
• Number of qualifying payments
Number of qualifying payments • See Direct Loans Only How to: Review
Payment Screens {bl(Bl
I
• See Direct Loans Only How to: Review Number
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of Qualifving Pavments when Borrower's

5
Loans are on COMPASS'M fbl( l I
• Qualifying loan types
• Qualifying repayment plans
General information about the PSLF
• Qualifying employment
program
• How to complete an ECF
• See FLSOnly Eligibility Requirements and FLS

Only: ECF
A1.14 L l FLS Only: How to Handle Calls Regarding PSLF Application

I KCID:
A draft of the proposed PSLFForgiveness application has been released. If you receive a phone call
from a borrower who accessed the draft application, advise the following:
• The form is ONLY a draft

• The borrower should not complete the application
The Department of Education is expected to release a finalized version of the form closer to the first
eligible date of forgiveness (9/02/2017).
A1.15 L Direct Loans Only: How to: Advise Removal of PSLF Paid Ahead
Status
b)(6)
Counsel the borrower on the benefit of opting to permanently remove the paid ahead status from
his/her account.
If Then
The borrower does not want to sign up

for Direct Debit Remove paid ahead status, as long as the removal
The borrower requests to remove paid of paid ahead will not cause delinquency
ahead status verbally or in writing
• This will maintain the required monthly installment amount, even if he/she pays more than
what is due.
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• If the borrower pays less than the monthly installment amount, the payment will not count
towards PSLF.
Examples:
• The borrower is due $SOon the 6th of the month

o Month 1: Borrower pays $60 on 1/10. The payment qualifies as one payment.
o Month 2: Borrower is billed for $40, but pays $60 on 2/6. The payment qualifies as one
payment.
o Month 3: Borrower is billed for $30 and pays $30 on 3/5. The payment does not qualify
because the borrower did not pay the full monthly installment amount.
• The borrower is due $50 on the 10th of the month
o Month 1: Borrower pays $150 on 1/10, satisfying the 1/10 due date plus the payment
due 2/10 and 3/10. The payment qualifies as one payment.
o Month 2: Borrower is billed for $0 and does not make a payment.
o Month 3: Borrower is billed for $0 and does not make a payment.
o Month 4:
• The borrower is billed $SOand pays $SOon 4/10. The payment qualifies as one
payment.
■ The borrower gets credit for two months: MONTH 1 and MONTH 4. If the
borrower had paid the minimum monthly installment due ($50) during months
two and three, the borrower would have additionally received credit for those
months as well (being paid ahead for two full months notwithstanding).
A1.16 L Direct Loans Only How to: Comment PSLF Accounts

~b)(6) I I
How the call is documented will depend on whether the loans are serviced by FedLoan Servicing or
another servicer.
If And Then
The borrower's loans are N/A Use Super Screen to comment the call
serviced by Fedloan from the borrower or the borrower's
Servicing employer (third party).
Comment the details of your call on

The borrower's loans are not
There is an employment the comment screen.
serviced by Fedloan
record on ITL2U
Servicing • From the ECFentry on l(bl(5l I
0 Press F4 to comment.
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0 Press the Home key. This will

move your cursor to the top
left of your screen. Change
the 'I' to a 'C' and press
ENTER.
0 Your comme □ t Ml ISI stact
with you:
fb)(6)
I
l(b)(6) ' I
0 Include all details.
0 Press ENTER to save your
comment.
Comment the details of your call on
the PSLFCALLCOMMENT l<b)(61 I
document. Document location:
fed loan_ operations$ b)(6)
fb)(6)
I
• Save the document to your
desktop.
There is no employment
• Drag the saved document to the
record on □ "Send to Imaging" application.
This will store the call comment in
Imaging Archive.
• The following attributes should be
used when sending the document
to archive:
(b)(6)
0
Comment all information in detail as discussed with the borrower/employer, including any
adjustments/requests. Include the following in every comment, if applicable:
• Your P or PH number
• Who you spoke to (specifically if employer calls).
• Specific information provided by the employer (if applicable).
• If the borrower was counseled on Consolidation, include if he/she was advised to include or
exclude Direct Loans.
• If the RVECFor RVWPS ARCs were populated to have the account reviewed further, include all
pertinent information related to this request.
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Consolidation
A1.17 L Direct Loans Only: Consolidating Direct Loans with Qualifying

Payments for PSLF
I KC,o,fb)(BI I
• Ask the borrower or check NSLDSto see if he/she already has Direct Loans.
• Talk to the borrower about his/her Direct Loans to see if he/she has been making payments.
• If the borrower has already made qualifying payments on his/her Direct Loans, he/she should
choose whether to include the Direct Loans in the consolidation. In some instances, this may
benefit the borrower (consolidating parent PLUS loans to qualify for ICR).
• Any qualifying payments the borrower previously made on his/her Direct Loans will no longer
qualify for PSLF.
• Include any counseling information in comments on the account
A1.18 L l FLS Only: Cautioning Borrowers on PSLF Consolidation

~I
•-c-,□-,-ccfb"'l(B"l---.,_j--~I
If Then
A borrower interested in pursuing PSLFhas He/she must consolidate the FFELPloans to
FFELPloans be eligible for the program.
The borrower includes Direct Loans in his/her Any previously qualified payments will no
consolidation, and he/she has already made longer qualify, as these loans will be paid in
qualifying payments towards forgiveness full once consolidation is complete.
A borrower has a variable interest rate It will be changed to a fixed interest rate.
• The fixed interest rate is based on the

weighted average of the interest rates
on the loans being consolidated,
rounded up to the nearest one-eighth
of 1%.
The service member's active duty start date is The borrower could lose SCRA benefit
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BEFOREthe disbursement date of the eligibility on a Direct Consolidation Loan.

consolidation
• Refer to Direct Consolidation Loan
Origination article (Pros and Cons
section) for more information.
A1.19 L l FLS Only: Loss of Borrower Benefits Due to PSLF Consolidation

~I .-c-,o-,~vb~)(-6)-----1--1
The borrower will lose any borrower benefits offered with the original loans, which may include the
following:
• Interest rate discounts
• Principal rebates
• Loan cancellation benefits:
o Borrower cancellation payments are only eligible for a period of 120 days after the
original disbursement date.
o Once the loans are consolidated, the effective date changes and the loan is no longer
eligible.
o Once the borrower consolidates, school refunds or borrower cancellations are not
applied to the account.
A1.20 L l FLS Only How to: Complete the PSLF Consolidation eApplication
I KCID,fb)(6)
If Then
The borrower selects that he/she is interested The borrower will be provided an option to
in PSLFon the Consolidation eApplication select a servicer from the list of consolidation
service rs
A borrower is consolidating a single FFELP He/she must:

loan for PSLFpurposes
• Download the form from the
studentloans.gov site
• Manually print, complete, and mail the
consolidation application.
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Note: Borrowers may consolidate a single

FFELPloan into a Direct Loan to become
eligible for Public Service Loan Forgiveness
(PSLF). However, the studentloans.gov
website does not permit electronic
consolidations for only one loan. There is no
anticipated date of correction.
Note: When the borrower applies for the consolidation on line, many borrowers may select "Yes"
to the "all of my education loans" questions.
• This prevents them from being able to differentiate/exclude his/her existing Direct Loans
from the consolidation.
• Answering "No" to the "all my loans" question prompts the borrower to decide what to do
with his/her Direct Loans and FFEL loans specifically.
A1 .21 L l FLS Only: Federally-Held Loans Not Yet Consolidated

rl-.c-,-o~,~r~b-)(=s_i~_-
_-_-_-_----~~I
_-__- ~_;-
Once an ECF is approved for a borrower, any federally-held loans he/she has, including his/her Direct
Loans, are transferred in approximately 30-60 days to our system. You may encounter an account
where it is past 60 days and the loans still have not transferred.
If Then
A borrower is approved for PSLFand then The borrower must submit a new ECFto have
consolidates ALL eligible loans his/her newly consolidated loan transferred
to us (only if the borrower is still employed
by a qualifying employer).
Borrower has Direct Loans and FFELPloans • Advise the borrower it will take 180+ days
and is approved for PSLF. for the loans to transfer from the date of
He/she consolidates ONLY his/her FFELP disbursement of the consolidation loan.
loans and the transfer to FLS is rejected • The Conversions department will request
the loans 180 days after the
disbursement.
A borrower's ECF has been approved and Access NSLDS to verify the loans are with a
he/she calls stating he/she has loans with DOE servicer.
another servicer
• If this is the case, send an email to the FLS
PSLFSupervisor Review mailbox
requesting to have the loans transferred.
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o Your email must include the

borrower's SSN, DOB, and full name.
o Once your email is received, we will
work with Conversions to have the
loans transferred.
• If the loans are FFELPLoans serviced by a
commercial servicer, advise the borrower
how to consolidate to make them eligible
for PSLF.
Payments
A1.22 L Direct Loans Only How to: View PSLF Payment Count on the FLS
Website
The borrower can view his/her PSLFPayment Count on the Fed Loan website.
• Payment count is broken down per loan under the Loan Summary Section.
o This section will display the number of qualifying payments made, the number of
qualifying payments remaining, and the estimated eligibility date.
If Then
The borrower submits an ECF • FLSwill estimate the date on which the
borrower will make their final
qualifying payment and become
eligible to submit their application for
forgiveness of the loans.
• This is based on the assumption that

the borrower will continue to work full-
time for a PSLFqualifying employer
until the time that he/she receives loan
forgiveness, while continuing to make
on-time, qualifying payments every
month until the time he/she applies for
loan forgiveness. This provides
borrowers with a more accurate
estimated eligibility date, depending on
the number of payments made without
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ECFcoverage.
The borrower views their qualifying They will be able to click on "What do
payments in the View Loan Details these terms mean?" to see a definition for
section on their online account the estimated eligibility date.
A1.23 L Direct Loans Only How to: Review Payment Screens (ITL2U)
~(b)(6)
I
1) Access the Public Service Loan Forgiveness Screen ~·
• Enter the Borrower's Account Number or SSN.
• Select the Payments option

• Press ENTERto navigate to the PSLFPayment Selection screen.
2) Review the PSLFPayment Selection Screen.
• The Payment Summary Screen is displayed and lists the following data:
Field Description
(b)(6)
Loan sequence number
First disbursement date
Loan program
Total Number of Qualifying Payments Made
Remaining Number of Qualifying Payments

Required
Expected Forgiveness Eligibility Date
Note: If the Expected Eligibility field is blank, the first review of eligible payments has not been
completed.
3) To view detailed payment information,
• Select the loan sequence number.
• Press ENTER.
• The target screen displays. This screen is loan specific and will need to be accessed for each
loan separately.
4) Review the PSLFTarget Screen.
• This screen displays the following fields:
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Field Description
(b)(6)
The number of automatically reviewed Pre-Conversion Qualifying
Payments.
The number of manually reviewed Pre-Conversion Qualifying

Payments as well as the number of Override Qualifying Payments.
The number of qualifying payments derived from an eligible

AmeriCorps or Peace Corps lump sum payment.
The total number of matched payments the borrower has made

while his/her loans were serviced by Fed loan Servicing that count
towards the 120 required payments. This field is automatically
calculated by the system.
The total number of matched payments received (addition of PCVN
QUAL, OVRD QUAL, CORP QUAL, and PYMNTS QUAL fields) out of
120. This field is automatically calculated by the system.
The total number of payments the borrower still needs to make to

qualify for forgiveness.
The date on which the borrower is expected to meet the program

requirements for forgiveness.
The begin and end dates of any previously approved period for
another forgiveness program [i.e. Teacher Loan Forgiveness (TLF)].
• To access the specific AmeriCorps/Peace Corps payment information
o Press F4=CORP.This screen will only be displayed when a lump sum payment was received.
(b)(6)
The certified service begin date
The certified service end date
The amount of the Award payment.
The date the Award payment was

received
The number of qualifying payments

resulting from the AmeriCorps/Peace
Corps lump sum payment
• To return to the PUBLICSERVICELOAN FORGIVENESSTARGETscreen
o Press F12=CAN.
Note: The borrower can view his/her PSLFpayment count on our website. See FLSOnly How
to: View PSLFPayment Count on the FLSWebsite
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• For additional guidance see the following:
o Direct Loans Only How to: Review Number of Qualifying Payments when Borrower's Loans
5I [
are on COMPASS'" ~(bl(
(b)(6)
o Direct Loans Onl : Pa ment Histor Task Created
A1.24 L Direct Loans Only How to: Review Number of Qualifying Payments
when Borrower's Loans are on COMPASS''' (ITL2U)
I KC 10:l(b)(6) I
When qualifying employment is established, we will determine if qualifying payments were made
within the employment period. Follow the directions below:
If Then Action
Fed Loan Servicing has COMPASS'M automatically Check to ensure the payments
serviced the loans since determines if any payments in question were made after
disbursement are qualifying: made on an the borrower's loans
eligible repayment plan, (consolidation) were
within 15 days of the due disbursed. Payments prior to
date, no earlier than 30 days consolidation do not qualify.
prior to the due date, and
during a period of qualified
employment.
Fed Loan Servicing has not COMPASS'M automatically Treasury Management will
serviced the loans since determines if any payments determine if the borrower
disbursement are qualifying since we began made qualifying payments
servicing the loans. prior to the date the loan was
added to COMPASS'" by
reviewing the imaged
conversion file.
A1 .25 L Direct Loans Only: Payment History Task (PSTRK) Created

I KC 10,i(b)(6)
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If the borrower did not previously have a relationship with FLS,once the loans convert from the other
servicer, the following will occur:
• A Welcome Letter is sent to the borrower

• The system will automatically count the payments made to the previous servicer that qualify
for PSLF.If the system does not count these payments, a queue task (PSTRK)is created to
trigger a review of history provided by the other servicer to verify/validate payments.
Note: The PSTRKtask will be reviewed by Treasury Management. Once their review is
completed, they will update the payment counter and a letter will be sent to the borrower.
A1 .26 L Direct Loans Only How to: Handle Borrower Call about Why Payment
Is or Isn't Approved for PSLF
I KC,ofb)(BI I I
The borrower may call to ask if/why a payment is/is not approved.
• Review the PSLFPayment Selection Screen (TL2U) in conjunction with the Payment History
screen, Repayment Schedule Screen, and the Billing Screen to determine why the payment
is/is not approved.
o For the Payment History Screen, see Direct Loans Only How to: Review the Payment
History Screen for PSLF
o For the Repayment Schedule Screen, see Direct Loans Only How to: Review the
Repayment Schedule History Screen
o For the Billing Screen, see Direct Loans Only Super Screen How to: Review the Billing
History Screen
• Prior to requesting a detailed qualifying payment letter, verbally review all of the payments to
try to eliminate the need for a detailed letter.
o Should the borrower still request the information in writing after the verbal review,
follow the directions below:
If Then
Borrower requests information to be Populate the PSCNTARC, indicating the

sent via US Postal mail borrower would like the PSLFQualifying
Payments Letter
Borrower requests information to be Populate the G307P ARC, indicating the

sent via email borrower would like the PSLFQualifying
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I Payments Email
A1.27 L Direct Loans Only How to: Review the Payment History Screen for
PSLF
The Payment History screen is reviewed to see if timely payments were made and is accessed through
Super Screen.
The Super Screen procedures can be found at: Digital Dashboard - Federal Super Screen User Guide in
Knowledge Base
1) To access the Payment History screen:
• Click Payment History under the Account Info section on the Info/ Actions tab.
• The Payment History window displays.
• The last 12 payments are displayed.

• Information displays in the following columns:
Rev Rea Reason for the reversal of payment
Code for the type of transaction
• When reviewing PSLFpayments, look for:
0 1010 (Borrower Payment, including Peace Corps

Tran Type payments) or
0 1035 (Segal AmeriCorps Education Rewards)
0 1034 (Non-Entitlement DOD or Peace Corps
Payment)
0 1037 (Entitlement DOD Payment)
Eff Date Effective date of the payment
Amount Amount of the payment
2) The View field defaults to 'All Payments.'
• For PSLF,always view 'All Payments.'
• Select the type of payments to be viewed from the drop-down list.
All Payments Displays all payments made to the account
Endorser Payments Displays only endorser payments
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Borrower Payments Displays only borrower payments
Borrower Behalf Payments Displays only borrower behalf payments
Borrower Cancellation Displays only borrower cancellation

Payments payments
• Double-click on a specific payment to view more details.
3) The Payment History window redisplays with the Payment History tab.
• The following fields are displayed in the Payment Breakdown section:
Disb Date First disbursement date of the loan

Loan Pgm Up to six-character abbreviation of the loan program
Owner Name of the owner of the loan
Principal Amount of the payment applied to the principal of the loan
Interest Amount of the payment applied to the interest of the loan
Amount of the payment applied to the late fees assessed on

Late Fees
the loan
Source Code for the source of the payment
• The Bill Cross Reference Section displays what bill the payment was applied to.
• The following fields are displayed in the Bill Cross Reference Section:
Date Create Date the bill was created and sent
Date Due Date the payment was due

Bill Type Type of billing
Amt Due Total amount due on the bill
Amt Satisfy Amount of the bill that was satisfied by the payment
A1.28 L Direct Loans Only How to: Review the Repayment Schedule History
Screen
I KC ID:!(b)(6)
The ITS2X Repayment Schedule History Screen is used to view a selected borrower's repayment
schedule.
• See ITS2X - Repayment Schedule Summary Selection for instructions on reviewing this screen.
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When assisting a borrower who has questions regarding his/her qualifying payments made to his/her
previous servicer, review the following steps:
1) Review the borrower's[bl( 5l ltask in File Net under the "FLSServicing" library
2) Ineligible repayment plans and qualifying employment periods are at the top of the worksheet.
• If the borrower is indicating a specific period ohime, this may explain why payments didn't
count.
3) Locate LJ to see if the employment period is in an 'A' approved status.
4) Make sure all ECFperiods are eligible and not in Review, Denied, or Conditionally Approved status.
• Until these are updated to an "Approved" status, we cannot process the payment tracking for
this ECF.
• Comments on the PSTRKtask in FileNet or i (bJ(Bl notations will show the time period of
employment that was used to count payments an why the borrower's payments qualify or do
not qualify.
5) Check~ for the re □ 11esj 5
(bl( l or for a previous response under fbl(6l
fb)(6) - ~--"
• This shows why certain payments or ECFperiods do not qualify.
• Treasury Management comments when a borrower has O payments, if there is an entire ECF
period covered by an ineligible repayment plan, or deferments/forbearances.
6) Chec~bl(BI IREPAYMENT START DATE/MAJOR BATCH ID
• This shows if the borrower was in repayment.
• Some borrowers will not go into repayment until a future date, and others are disbursed by
FedLoan Servicing
• If the Major Batch Id is blank, these loans are disbursed by FedLoan Servicing and our system
should be counting the payments. No PSTRKtask is needed.
7) If you are not able to determine if a payment is or is not approved,
•
kb)(6)
Populate thecl ____
I
Jthrough L~__
ITT(6f"7
lo have the information reviewed/updated:
o Access~
o F8 to page forward and select the "Wbl(6l lby entering 01 on the line and press
enter.
o Select all loans with a balance with an "X"
o Type the details of your request in the message text area

o Press Enter.
o Advise the borrower his/her request will be reviewed.
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• Comment thE;t=b~l(6~1-~~ask
with the following information:
o The specific ECFperiod

o The specific loan sequences
8) Advise the borrower he/she will receive a call back once the review is complete.
Note: If Treasury Management is unable to determine if the payment qualifies, they will
escalate the non-approved payment to Federal Student Aid (FSA)for Review.
A1 .29 L Direct Loans Only Super Screen How to: Review the Billing History
Screen
The Billing History screen is used to view the billing/amount due while serviced with FLS.
1) Click Billing under the Account Level Summary Section in the Info/ Actions tab.
• The Billing Information window displays.
• The following columns display for each loan:

(b)(6)
Loan sequence number
First disbursement date of the loan

Up to six-character abbreviation of the loan program
Type of billing for the loan
Type of bill - INTEREST, INTEREST NOTICE or INSTALL

(Installment)
Create date of the bill
Next payment due date
Amount past due on the loan
Current amount due on the loan
Total of the past amount due and the current

amount due
Number of days the account is delinquent
First date of delinquency on the account or first

payment date that was not fully satisfied
Late fees assessed on the loan
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2) Click History/Bill Recipient to view the history of billing for the account.
• The Billing Information window redisplays.
• The History and Billing Recipient section displays the following fields:
(b)(6)
Date the payment was due for the bill
Create date of the bill
Total amount due to satisfy the bill
Late fees assessed on any past due bills
Name of the billing recipient
Type of billing statement
Displays YES if the bill was reprinted

Note: Use the scroll bar to scroll through the list of past bills.
Note: As of June 2016, monthly billing statements will now include the total number of
qualifying payments a borrower has made toward PSLF
A1 .30 L Direct Loans Only: Call Regarding Payments While on In-School

Deferment
I KC ,oJ'l(BI
If Then Action
The borrower calls in and • Send an In-School 1) Submit thefbl(Bl

I
indicates he/she was placed on Deferment Waiver to through fbl(6l 1once the
an In-School Deferment but allow the borrower to verbal request is received
continued to make payments permanently request
that an In-School
The borrower calls in and 2) Comment the request
Deferment wouldn't be
indicates he/she was placed on with the effective date in
applied in the future
an In-School Deferment, and which the borrower is
would like to resume making • A request to waive the requesting
payments current In-School
Example: Borrower
Deferment can be taken requests In-School
verbally or in writing
Deferment Waiver to be
effective for 06/07/2011.
• All In-School Deferments on the account, beginning with the effective date the borrower
requested, will be removed
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• A form will be sent to the borrower via paper mail to be signed and returned. This form
cannot be sent via fax or email.
• If the borrower fails to return the signed In-School Deferment Waiver, and new enrollment
is received from the school, the In-School Deferment will be placed back on the account.
Escalated Calls
A1 .31 L Direct Loans Only When to: Transfer a Call to PSLF Split
I KC 1D,1(b)(6)
Note: If you receive a call intended for a specialty split, and you are trained on the specialty split, no
transfer is necessary. You should continue with the call, answering the specialty split questions.
If Then
1) The borrower is requesting specific You must COLD transfer the call to the PSLF
information concerning PSLF,such as: split, j{b)(B) I
a) What is the status of my ECF?
b) How many of my payments qualify?
c) I received a letter telling me I have XX
payments that qualify, but I want to
know why the rest of my payments
don't count?
d) Why was my ECFdenied?
e) Does my employer qualify?

f) When will my loans be transferred?
g) When will I be notified of how many

payments qualify?
2) The borrower states he/she received a Ask the borrower if the letter received
letter, but you are unable to locate an references the PSLFprogram. Proceed to step
account for them a) below.
a) The letter references the PSLF Advise the borrower that you will be
program transferring them to a dedicated PSLF
representative for further assistance. COLD
transfer the call to the PSLFsplit~
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A1.32 L Direct Loans Only When to: Escalate a Call to PSLF Escalated Split
I KC 1□ ,1(b)(6)
I I
If Then
A caller requests to speak to someone at a Transfer the caller to the PSLFEscalated Split:
higher level than the initial contact regarding Extension l(bJ(6J I
any PSLF-related topic • This split is available only for
representatives receiving calls at
extension~
• Only use for escalated calls
0 View the Phone Call Transfers
and Holds Landing Page in
Knowledge Center for guidance
on transferring the call.
0 Do not blind transfer the call

Note: This team consists of highly specialized
representatives who are specifically trained to
deal with PSLF-related issues
A1.33 L Direct Loans Only How to: Handle Expedited PSLF Requests When an
Expedited Request Already Exists on the Borrower's Account
I KCID: h1/R1
If And Then
The borrower is • I
The (b1(61 task is Send an email to thEfbl(5l I
requesting to have his/her already on the account Servicing mailbox:
payment tracking • It has been greater
1) Type ~ o access the
than 90 days from the
expedited appropriate mailbox
initial payment
tracking review
2) Include the following
information:
• Details of the review
• Borrower's full name
• Borrower's SSN
Employment or an ECF Send an email to the FLS PSLF
N/A Supervisor Review mailbox
needs to be reviewed for
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a non-FLS borrower
A1.34 L Direct Loans Only How to: Handle Additional PSLF Review Requests
I KC10,['i(B)
I
If And Then
There is a PSLFSpanish call N/A Send an email to the FLS PSLF
back request Supervisor Review mailbox
There is a loan transfer The transfer has taken Send an email to the FLS PSLF
request longer than 60 days from Supervisor Review mailbox to
uested date on request that the non-FLS
0 I
borrower's (not serviced on our
system) federally-held loans be
transferred from his/her
current servicer
The employer calls back with N/A Send an email to the FLS PSLF
updated information Supervisor Review mailbox
Submitting Review
A1.35 L Direct Loans Only When to: Submit the RVWPS ARC
I KC 10:fb)(6)
I 1
Do not offer the option of expediting the review process to borrowers. Explain that the current
processing time is approximately 70-90 days for the initial payment tracking review to be completed.
Prior to submitting arb)(B) Iyou MUST check for the following:
1) Check to see if the payment tracking is waiting to be processed. For pending requests, a PSTRK
task will be open on~
2) Check for pending ~Tasks. These will be processed within 90 days.
3) Check to see if the borrower was on an eligible repayment schedule during the dates of his/her
approved ECFthat is on file.
4) Check to verify there is an approved ECFon file for the time period in question. Payments that are
not covered by qualifying employment cannot be counted.
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5) Check to ensure the payments in question were made after the borrower's loans (consolidation)
were disbursed. Payments prior to consolidation do not qualify.
Note: To provide a detailed comment, obtain the following:
• Specific time frames from the borrower that he/she does not agree with
• Specific ECF periods.
• Specific loan sequences
6) Check to see if payment tracking was already completed by reviewing~o see that the
payment count was updated.
If Then
The payment tracking has been completed Do not submit a task for review
The payment tracking has been Submit the request for review. Specify the
completed, but the borrower is disputing following:
the payment count • Reason
• Payments made
• Time period the borrower is
disputing
The payment tracking has NOT been Do not submit a task for review
completed, and is less than 90 days
The payment tracking has NOT been Submit the request for review. Specify that
completed, and is more than 90 days the payment tracking request is greater
than 90 days.
(b)(6)
7) 0 nee the payment tracking task is complete, populate thE o comment the closed
pa yment tracking task.
• Treasury will not comment on the payment tracking task as this is now automated through a
script the following day that a task is closed.
Note: Effective 07/20/2016, if a blank task is created in the RVWPS queue, we will be closing the
task as no adjustment and submitting al(bl(6l I
A1.36 L Direct Loans Only When to: Submit the REVCF ARC
I KCID:l(b)(6)
I 1
Populate the RVECFARC when:
• A borrower or employer calls regarding employer eligibility.

• A borrower or employer is requesting the ECFto be reviewed further.
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A1.37 L Direct Loans Only When to: Submit the PSREV ARC
I KC ID:jtb)(6)
I
Populate the PSREVARC when:
• Issues with repayment schedules require additional review.

• Accounts need reviewed for PSLFissues due to errors with IDR processing.
o Examples:
■ Payments made during IDR and do not currently count towards PSLF
■ IDR not processed timely or correctly
• Borrower requests to opt out of PSLF.
o Notate why the borrower is requesting to opt out.
• Populate the PSREVwith the month(s) a bill is being requested when:
o Borrower's loans were released within the last 30 days
o Borrower did not receive a bill for the month(s) of the transfer
o Borrower is requesting a bill
• Borrower is requesting to have the account re-disclosed on a qualifying level repayment
schedule (with the condition that the borrower would repay the remaining balance on the
loans within a 120 month term based on the term that is remaining).
• When any of the following are received to review eligibility of employment/inconclusive status
in the database:
o W-2s
o Pay Stubs
o Proof of Qualifying Public Service
o Proof that the organization is no longer operational
A1.38 L Direct Loans Only When to: Submit the PSNPR ARC
I KCID, fb)(6) I
This ARC is used to track Non-Profit 501(c)(3) employers who have previously been approved in the
PSLFOrganization Database.
• Upon receiving additional ECF'sfrom these employers, PSLFLeads will review them to ensure
they have maintained his/her 501 (c) (3) status with the IRS.
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Populate the PSNPR ARC when:
• The "Date Approved" in the PSLFOrganization Database is greater than one year from the date
the new ECF is received.
A1 .39 L Direct Loans Only PSCBK: PSLF Call Back Request

I KC ID,t')(6) I I
~--~
Do not populate the PSCBKARC. This ARC should ONLY be populated by Treasury Management once a
RVWPS task has been completed, or placed on hold due to waiting for conversion files from a previous
servicer.
• The Borrower calls in to have payment tracking expedited, or payment count further reviewed
because of new information received, or he/she does not agree with his/her payment count.
• PSLFRep takes call and then populates the RVWPS ARC to have his/her payment tracking
reviewed
o Representative in Treasury Management will work RVWPS Task
• Once RVWPS Task has been completed or placed on hold (usually due to missing conversion
files), they will populate the PSCBKARC.
o PSCBKtasks will be assigned daily.
• Once the PSCBKtask is assigned, you will be sent an email letting you know the call back needs
to be made.
Opt-Out
A1 .40 L Direct Loans Only: Call Regarding Opting Out of PSLF

I KC 10,~t'_)(6-)--~I I
After explaining the requirements of the program, some borrowers may find that he/she cannot
afford an eligible repayment plan, or that he/she will not have a significant balance after he/she
makes 120 payments.
In these cases, some borrowers have determined that after reviewing his/her options he/she will not
benefit from this program. Borrowers may also be prompted to opt out after receiving an email about
the PSLFProgram.
If Then
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If the borrower decides he/she no longer wants • He/she can opt out. By opting out, nothing
to pursue PSLF changes on his/her account. We cannot
"cancel" a borrower from PSLF.
• His/her loans will remain serviced by FLS, but
we can place the 'PSCNL' ARC on the account
to ensure future PSLFcommunication is not
sent to them.
• See Direct Loans Only: Borrower Chooses to
0Qt-out of PSLF
A new ECF is received after the PSCNLtask is It is processed as normal. The borrower will
populated resume receiving emails and other PSLF
communication, if approved.
The borrower does not submit any more ECF'sto We will not send any more approval letters or
FLS payment tracking letters.
We do not currently service the loans for the • Send an email to the FLS PSLFSupervisor
borrower requesting to "cancel" PSLF Review in box. Ensure the account is fully
commented as to why the borrower is
requesting to cancel.
• DO NOT advise the borrower that the loans
will not transfer to FLSfor servicing.
A1.41 L Direct Loans Only: Borrower Chooses to Opt-out of PSLF

I KC ID,!{b)(6)
I I
If Then
You are speaking with a FLSborrower who no • Populate the PSREVARC.

longer wants to pursue PSLF • In your comment, include the reason he/she
no longer wants to pursue the program.
The loans have not transferred to FLSand the • Send an email to the FLS PSLFSupervisor
borrower no longer wants to pursue PSLF Review mailbox.
0 Include the SSN and reason why
he/she no longer wants to pursue the
program.
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• We will reach out to Conversions to

determine if we are able to stop the loan(s)
from transferring
We are able to stop the transfer A letter is sent to the borrower advising his/her
loans will not be transferred and will remain with
his/her current servicer
We are not able to stop the transfer The borrower will be sent a letter advising that
his/her loans are being transferred since he/she
completed the ECF,and his/her loans will remain
with FLS.
Non-Core Information
A1.42 L Direct Loans Only: PSLF Email Campaign

I KC1o!(bl(BI I I
Receive Emails Do Not Receive Emails or Letters

Borrowers who are not on a beneficial repayment • Borrowers who have an open I DR task
plan and who: waiting to be processed.
• Are currently making payments on an • Borrowers who are currently on a
eligible plan (i.e. Standard) but will have deferment/forbeara nee.
little to no benefit after making the
required 120 qualifying payments. • Parent PLUS loan borrowers .
• Are not on an eligible plan at all (i.e .

Graduated) who will not have any
qualifying payments counted unless
he/she switchs his/her plan.
• Note: The emails will be logged on the account history under the following ARCs:
5
o Plan Not Beneficial (ARQL(b_l(
_1_J
o Plan Not Eligible (ARC:fb)(61
• PSLFemails for a borrower on ineligible or non-beneficial repayment plans are sent quarterly
to each borrower that hasn't received an email within the past 3 months.
• Once the loan is in a released status with greater than $0.00 balance and we have an approved
ECFon file, the borrower will receive an email independently, on a quarterly notice.
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• The borrower will not receive the SAME email or corresponding letter twice within a 90 day
period.
• The borrower will be identified on day 91 if his/her repayment schedule has not changed to an
eligible & beneficial plan and sent another email.
Note: A borrower who does not have a valid email address on file or had previously
requested to 'unsubscribe' from our emails will receive a letter instead.
A1.43 L Direct Loans Only: PSLF Annual ECF Recertification Email Campaign
I KC ,or)(6) I
~---~
Emails are sent annually to borrowers who last had an ECFapproved one year ago to encourage the
borrower to submit a new ECFas a way to better track qualifying payments toward PSLF.Once this
email is sent, it is notated under the ECl 71 ARC.
Note: In some cases receiving one of the emails may result in the borrower deciding to opt out of PSLF
because the borrower does not feel it benefits him or her.
A1.44 L Direct Loans Only: Super Screen Disposition Codes

I KC ID: [b)(B)
I I
Super Screen disposition codes are available to provide better tracking specific to PSLFphone calls.
• There are four options available when you select PSLF.Each option has its own list of
disposition codes to describe the outcome of the phone call.
o Consolidation
o ECF
o Qualifying Payments
o Repayment Plan
A1 .45 L Direct Loans Only: Calls Regarding Natural Disasters

I KC 10,Ll(b-)(6_)_-~I I
FSA is giving PSLFborrowers, who meet certain conditions, an extension to make qualifying payments
for PSLFin the event he/she is impacted by a Natural Disaster.
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• The account will be reviewed to determine if the payment will qualify. Once the review is
complete, we will call the borrower to advise the outcome of the review.
If Then
A PSLFborrower is living in an area affected by a • Apply a Disaster Forbearance to the account

major disaster (and designated by Federal based on normal procedures
Emergency Management Agency (FEMA) for • However, the borrower must be made aware
"Individual Assistance") contacts us, and asks that payments made during the Disaster
for temporary relief due to the disaster Forbearance will not count towards PSLF.
A PSLFborrower pays his/her payment late We may be able to count the payment as a
during this time period qualifying payment
A borrower living in an affected area makes The payment will count as an on-time payment if
his/her otherwise qualifying payment more than it is made during the 30-day period following the
15 days after the due date, but within 20 days of date that the disaster was declared.
the due date
Borrowers request and receive a major disaster Borrowers will not receive credit for a PSLF
forbearance (or any other deferment or qualifying payment
forbearance) during the 30-day period following
the disaster declaration, or make a payment
more than 20 days after the due date
The Department of Education notifies us to • PSLFpayments made during the forbearance

place a disaster forbearance on all borrowers will not count as qualifying PSLFpayments.
living in the designated area • However, a borrower can ask that we remove
the forbearance since he/she didn't ask for it,
and the payments could count as qualifying
payments if he/she meets all other
requirements of a qualifying payment.
We are unable to determine if an impacted We will count the payment as a qualifying PSLF
borrower lived in a designated disaster area payment only if:
• The borrower notifies us that he or she lived

in a designated disaster area at the time of
the disaster; and
• We attempt to verify the borrower's claim
through available information in the
borrower's account history.
The borrower contacts us requesting to have a Populate the PSREVARC. In your request,
payment that may fall in this scenario count for include:
PSLF
• The type of disaster,
• When the disaster occurred, and
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• The payment date and amount in question.
Section A2: L Direct Loans Only: Public Service Loan

Forgiveness (PSLF) Employment Landing Page
I KC ID, fb)(6)
ECF
A2.1 L Direct Loans Only: Refer the Borrower to the FLS Website for an ECF
I KC 10,fbl(BI
I
We must supply the ECFto a borrower upon request. The cover page included with the ECFhas
instructions for completing the form.
Refer the borrower to the Loan Forgiveness section of our website for the ECF,regardless if the
borrower's loans are currently serviced by Fed Loan Servicing.
If And Then
The borrower's loans are Offer to email or mail the
currently serviced by Fed loan information
Servicing The borrower cannot download • See Direct Loans Only
The borrower's loans are NOT the ECF How to: Manually Send
currently serviced by Fed Loan the ECFto FLS Borrowers
Servicing
A2.2 L Direct Loans Only How to: Navigate the FLS Website to Answer
Employment Certification Form Questions
I KC 10,1(b)(6)
To assist borrowers with PSLFquestions, direct the borrower to our website.

Borrowers must download the Employment Certification Form to begin the forgiveness process.
1) Locate this form from the home page by accessing 'Public Service Loan Forgiveness' under 'Special
Programs'
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2) Scroll down the page and locate 'Completing the Employment Certification Form (ECF)'
3) Select 'Complete Your ECFNow'
4) Select 'ECF' under 'Print the following documents' to download the PDF
Notes:
• This form must be completed each year the borrower is employed by a Public Service
organization.
• Once the ECFform is processed, the borrower will receive confirmation of qualifying
employment and qualifying Direct Loan payments (if applicable).
A2.3 L Direct Loans Only How to: Manually Send the ECF to FLS Borrowers
I KC ID:l\0)(6)
I I
For FLSborrowers, see the table below for available options to send an ECF:
Option Action
Send via E-mail :,end the ECFusing the forms/links macro on
ISuper Screen.
• See SuQer Screen User Guide for instructions .
Send via Mail ISendthe ECFthroughl(bJ(6J ~ populating the
PSLFAARC.
Note: When sending a manual letter to a borrower, do not use the SSN. Use the borrower's account
number.
A2.4 L Direct Loans Only How to: Manually Send the ECF to Non-FLS
Borrowers
I KC ID· j(b)(B) ~q
For Non-FLS borrowers, send the ECFmanually:
1) Locate the ECFCover Letter.

2) Enter today's date at the top of the letter (MONTH DD, YYYY).
3) Enter the borrower's first and last name.
Note: The name must be in all capital letters.
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4) Enter the borrower's address in all capital letters with no punctuation.
5) Once the letter is completed, save it in the 'PSLF Letter QA' folder:
• Save the document as your first initial, last name, date, and SSN.
• If the borrower did not provide his/her SSN,save it as your first initial, last name, and date.
6) A QA (Quality Assurance) representative will review the letter.
If Then
Errors are found • The QA representative will correct the

errors
• Once the letter is correct, the QA
representative will image, print, and mail
the letter to the borrower. You will be
alerted of the error via the QA database.
No errors are found The QA representative will image, print, and

mail the letter to the borrower
A2.5 L Direct Loans Only: PSLF ECF Update

I KC ID=r)(B)
I I
On 2/17/2016, the Federal Student Aid (FSA) released an updated PSLFECF.

• The updated form includes REPAYElanguage and the removal of Box 15 in Section 4.
If Then
The borrower has an older version of the
ECF(with box 15),
dvise the borrower to download and
The borrower is asking about completing
complete the new form.
an ECF,and he/she has the form that
expired 11/30/2014,
A2.6 L Direct Loans Only: Advising the Borrower How to Complete the ECF
I KC 10:fb)(6)
I I
• Advise the borrower that Sections 1 and 2 MUST BE completed, including the following fields:
o Social Security Number.
o Date of Birth.
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o First and Last Name.

o Borrower address.
o Borrower phone number.
o Borrower signature.
o Borrower signature date.
Note: Borrower's email address is optional
• Section 3 is completed by the borrower or employer. The following fields MUST BE completed:
o Employer Name
o Federal EIN
o Employer Address- If only a partial address is listed, this is acceptable. Examples of a
partial address include one or more of the following:
• Street address
• City
• State
• Zip Code
o Employment Begin date

o Employment End date (or the 'Still Employed' box must be checked)
o Employment Status box: Full-Time or Part-Time
o Hours per Week
o Questions 9-14
• Some questions will not need to be answered. For instance, if the
borrower/employer checks 'yes' to question 9, he/she does not need to
complete questions 10 -14.
Note: Employer website is optional
• Section 4 must be completed by the employer. The following fields MUST BE completed:
o Authorized Official's Name
o Authorized Official's Title
o Authorized Official's Signature
o Authorized Official's Phone
o Date Completed
Note: Authorized Official's Email is optional
Note: The borrower or employer MUST initial any alterations he/she makes to any information
he/she provided on the ECF.
A2.7 L Direct Loans Only: How Often a Borrower Can Submit the ECF
I KC ID, fb1(6) I I
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Fed loan Servicing (FLS) has no specific requirement for the frequency the borrower submits the
Employment Certification Form (ECF)
• FLSsuggests borrowers submit an ECFonce a year for the prior year of employment to keep
his/her employment status current.
• FLSsuggests borrowers submit an ECFwhen he/she first applies for the PSLFProgram and
when he/she changes employers.
• ECFsubmittals allow FLSto track periods of qualified employment and the number of
A2.8 L Direct Loans Only: Determine if the ECF Was Received

I KC 10,1(b)(6)
I I
The ECFcan be returned by mail, fax, or e-mail.
• Advise borrowers to refrain from sending personal information via e-mail. We cannot
guarantee security against interception by unauthorized third parties.
Note: Fed Loan Servicing is not responsible for undelivered, lost, misdirected or intercepted
mail, faxes or e-mails, but will make every effort to keep the borrower's information secure.
The ECFwill be imaged under the Doc ID XBCR and PSECFARC.
Note: Super Screen has an alert to indicate that a PSLFborrower submitted an ECFand has an
approved ECFon file.
This alert does not require a transfer to the PSLFSplit.
A2.9 L Direct Loans Escalated Situation Only How to: Image an ECF
I KC 10,!(b)(B) I
• Save the document to your desktop.
• Drag the saved document to the "Send to Imaging" application.
• The following attributes should be used when sending the document to archive:
0 (b)(6)
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A2.10 L Direct Loans Only COMPASS' 11

• How to: Review ECF on ITL2U
I KC 1□ ,1(b)(6) I
1) Access COMPASS'M and region.
• Additional information pertaining to completing these steps is available in the COMPASS'M

Navigation Guide, located in Content Connection.
2) Open COMPASS'".
• Locate Launch Pad.

• See the FLS Knowledge Base article Single Session HERA- New Shortcut for assistance
3) Log into COMPASS'".
• LOGON- PHEAA
•
=~----------------------------~
USER ID - (bJ(Bl
(b)(6)
• PA SWORD - Enter the password.

• Press ENTER.
4) Access the appropriate region.
• To access the FD Region, type STUPFD.

• Press ENTER.
5) Acces: the Public Service Loan Forgiveness Screen~n COMPASS'M

to answer the caller's
questions. L__J
• Enter the borrower's Account Number or SSN.
• Select the Employment Record option and press ENTER.
Note: Employment data will display only if the borrower submitted an ECFthat has been
processed.
A2.11
c::«:m:1(b)(6)
L Direct Loans Only: ECF in Approved (A) Status
KCID
I I
If Then
Status is Approved (A) ECF is approved. An approval letter is generated.
The loans are not serviced The letter will advise the borrower that his/her loans will be transferred
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by Fedloan Servicing to us, and we will notify him/her regarding:

• Number of qualifying payments made to date
• Number of payments remaining of the required 120
• He/she will be required to apply for PSLFafter the 120 qualifying
payments have been made
A2.12 L Direct Loans Only: ECF in Denied (D) Status

I KC ID:l(b)(6)
I I
If Then
Status is Denied (D) ECFis not approved. A denial letter is generated.
The borrower does not The reason(s) is listed
qualify
Information is missing The missing information is listed and the letter will explain the steps the
borrower may take to have the ECFreconsidered
The denial letter is by- A manual letter will be sent to the borrower to advise if additional
passed information is needed or the detailed reason for not being eligible. This
can be identified by reviewing the TL2U screen, 'BYPASS LTR' field will
be populated with a 'N' if the letter has been bypassed.
A2.13 L Direct Loans Only: ECF in Conditionally Approved (C) Status

I KC
,or(B)
~----~ 1
ECFis approved, but the employment hours are listed as part-time.
• A letter is generated advising that although the employer qualifies, the employment period
can't be used to match qualifying payments because he/she is not employed full-time.
• To have this time period qualify for PSLF,the borrower must provide another ECFcertifying
another part time position that overlaps the same period, provided the combined total hours
of employment is at least 30 hours per week.
A2.14 L Direct Loans Only: ECF in Hold (H) Status

rl -.c-,-o.,f"'1("'s1---------,p
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• Processing or initial review has not been completed.

• The employment record is placed on hold until the processor is able to complete or determine
if the employer needs reviewed for eligibility in the Employer Database.
• No letter is generated when the record is placed in a hold status.
• When processing is resumed the Form Status Field will be changed to A, D, C, or R.
A2.15 L Direct Loans Only: ECF in Review (R) Status

~b)(6) I I
~---~
• The employer's information needs to be reviewed for eligibility.
• The task is placed on hold until the review is complete.
• A letter is generated informing the borrower that we are unable to determine if his/her
employer is approved at this time and he/she will be notified when a determination is made.
• When a determination is made, the Form Status Field will be changed to A, D, or C.
A2.16 L Direct Loans Only How to: Handle Call Received from an Employer to
Complete ECF
I KC 10:fb)(6)
If you receive a call from an employer, access the MACRO through the LAUNCH PAD located on your
desktop.
1) Once the Launch Pad has opened, expand the "Processing Tools" option.
2) Select "PSLFCallback" option.
• The Macro should open to the main screen.
3) Obtain one of the following pieces of information from the Employer:
• Borrower First Name
• Borrower Last Name
• Employer Name
• Official Name
• Last 4 of SSN
4) Once the information is obtained, enter it into the corresponding field at the top of the Macro
• Press the Search button.
o The search results will display in the right hand box, below the search fields.
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• Select the record you want to update and double click.

o The borrower's information will prepopulate in field to the right of the search box.
• The missing information will be displayed below the search box.
• If the box is checked, that piece of information will need to be obtained from the employer.
5) Enter the information obtained into the corresponding field.
• If all of the missing information is received during the call, check the 'All Missing Information
Received' box.
6) Press Update.
7) Once the record has successfully updated, you will received a pop-up box. Click 'OK.'
8) Click 'Reset' at the top to begin the next search.
Note: Comment the account with the information received.
If Then
Populate thel(bl(6l
FLSBorrower I
Non-FLS Borrower Send an email to the FLSPSLFSupervisor
Review inbox
Employer Qualifications
A2.17 L Direct Loans Only: PSLF Qualifying Employment

I KC ,o,fbl(BI
I I
The borrower must be employed full-time by a qualified public service organization(s) or serving as a
full-time AmeriCorps or Peace Corps volunteer while making the 120 qualifying payments.
Note: If a borrower works part-time for 2 or more qualifying public service organizations, the
employment is considered full time if the sum of the average hours between the qualifying employers
totals at least 30 hours per week.
A2.18 L Direct Loans Only PSLF Qualifying Employment: Government

Organization
I KC 10,1(b)(6)
See the table below for acceptable organizations under Government organizations.
I Includes I Excludes
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• Federal ~ member of the U.S. Congress (Senator or

• State Representative)
• Local • Congressional staff members and state
legislators (and their staff) may qualify
• Tribal Organization
• Public child or family service agency • Exception: Any period of time the borrower
worked for a political or (re)election campaign
• Tribal College or University
• AmeriCorps
• Peace Corps
A2.19 L Direct Loans Only PSLF Qualifying Employment: Non-profit Tax-

Exempt Organization Under 501(c)(3) of the Internal Revenue Code
I KC 10, Kb1(6) I I
Acceptable organizations under Non-profit, tax-exempt organization under Section 501(c)(3) of the
Internal Revenue Code includes most not-for-profit private schools, colleges, and universities.
Note: A 501(c)(3) organization only qualifies if the borrower's qualifying employment does not include
time spent on job duties that are related to religious instruction, worship services, or any form of
proselytizing.
A2.20 L Direct Loans Only PSLF Qualifying Employment: Private, Not-for-

Profit Organization
I KC ID: !(b)(6)
If an organization is not-for-profit, but is not a 501(c)(3) organization, it could qualify as a private, not-
for-profit organization as long as the organization provides one or more of the following types of
qualifying public service:
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated child care, Head Start, and State
funded pre-kindergarten)
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• Public service for individuals with disabilities

• Public service for the elderly
• Public health (including nurses, nurse practitioners, nurses in a clinical setting, and
professionals engaged in health care-practitioner occupations and health support-occupations,
as defined by the Bureau of Labor Statistics)
• School library services
• Other school-based services
Note: A not-for-profit organization only qualifies if the borrower's qualifying employment does
not include time spent on job duties that are related to religious instruction, worship services, or
any form of proselytizing.
A2.21 L Direct Loans Only PSLF Qualifying Employment: Supporting

Documentation
I KC,o,fbl(BI
The borrower must provide supporting documentation to show employment at a qualified public
service organization, including:
• A completed, signed, and dated ECFby an authorized official from a validated qualifying public
If Then Action
If the borrower is unable to The borrower must provide • The borrower must submit
obtain certification because the evidence that: a separate W-2 for each
organization no longer exists or • The employer was a year being certified. If the
the employer refuses to certify qualifying public service borrower does not have
organization. W-2s, Paystubs may be
acceptable in certain cases.
• The borrower was
Note: The EIN from the W-
engaged in paid
employment for the 2 will be used to determine
indicated period. if the employer qualifies.
The W-2 will be used in
• The borrower was
conjunction with the
employed in a full-
paystubs to
time/part-time position,
verify/calculate whether
as indicated on the ECF
the borrower was
employed full-time hours.
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The W-2 by itself shows

only where the borrower
was employed and not that
an employer was a
qualifying public service
organization.
A2.22 L Direct Loans Only How to: Determine if the Employer Qualifies
KC ,o:rb)(6)
1
1) Obtain the following information for the organization from the borrower:
• Full name of the organization.

• Full address of the organization in which it is located.
• EIN
2) Review and access the PSLFDatabase (Employer Database) to verify qualifying employers and/or
to have an employer reviewed.
• The PSLFDatabase contains a list of employers who have been escalated for further review.
An employer can show one of 4 statuses: approved, denied, inconclusive, or currently under
review.
• Open the Employer Database by accessing the MACRO through the LAUNCH PAD, located on
your desktop.
• Expand the "Processing Tools" option
• Select the "PSLF Organization Database" option
3) Click "Clear Filter," located at the bottom of the database, to ensure you are searching the entire
database.
4) Select 'EIN Filter,' enter the EIN in the 'Search' field, and press 'OK'
If Then Example
We are searching for EIN 586000134.
• Since the organization for this
EIN has already been added,
Performing multiple Press the 'Clear Filters' button the EIN was located.
searches o begin a new search • To view the details regarding
the status of this employer,
select the view detail button.
5) Determine if the employer qualifies
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• If the employer (same name, location, and EIN) has already been approved or denied, advise
the borrower of the decision that has been previously made.
6) If an exact employer match is not found in the Employer Database, review the directories for each
category of employer to determine if the organization is a qualifying public service organization.
A2.23 L Direct Loans Only How to: Review Directories for Federal, State,
Local or Tribal Government Organization, Agency, or Entity
I KCID, fb1(6)
• Check if the Federal, State, local or Tribal government organization, agency or entity is listed
on the following directory: http://www.usa.gov/Agencies.shtml
Note: You can access the state government website for each state by selecting the
"State Government" link from this site.
• For additional information regarding these types of organizations, see the table below:
Employer Additional Information

Public child or family services • When reviewing an employer that may be
agency run by government, it cannot be assumed that the
state/county/ city /tri ba I employer qualifies because it appears on a state
website.
government
0 The employer needs to have been organized
under statute or be a political subdivision,
etc. in order to be approved under
government.
0 The actual organization's website must be a
.gov website.
• Employers listed on government websites that are
typically not governmental entities are nursing
homes and daycare centers.
0 Nursing homes and daycare centers often
appear on a state website because they are
licensed by the state, not because they are
governmental organizations.
Tribal college or university Access the website:
htt~:LLwww.ed.govLedblogsLwhiaianeLtribes-tcusLtribal-
colleges-a nd-u n iversitiesL
Public schools, universities, school Access the National Center for Education Statistics website:
htt~ :LLnces.ed.govLglobal locator L
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districts, and libraries

Military Branch (including Army, These types of employers are approved.
Navy, Air Force, Marines, Coast
Guard, State National Guard)
Affiliated with the U.S. Congress • Email the information to the "FLS PSLFSupervisor
(U.S. Senate or House of Review" mailbox for further review.
Representatives) • Advise the borrower you will call them back once
guidance is provided.
A2.24 L Direct Loans Only How to: Review Directories for Non-Profit
501 (c)(3) Organizations
1
KC ,o,rb)(6) 1
Follow directions below for reviewing the Directories for Non-Profit 501(c)(3) Organizations.
1) Access the Internal Revenue Service (IRS) Exempt Organizations Select Check Tool with EIN codes.
2) Search the IRS database to determine if the organization is listed as having S0l(c) (3) status
• Select the "Are eligible to receive tax-deductible charitable contributions" option using the
"radio" button on the web page.
3) Search using the Organization's EIN.
4) See the table below:
If Then
The deductibility status code is listed as "PC," The organization qualifies for PSLFand is
registered with the IRS as a public, non-profit
organization.
An organization is listed with a deductibility The employer must be further reviewed.

status code other than "PC," Advise the borrower to submit an ECF.
The organization is not found using 1) Access the IRS EO BMF website
Publication 78,
a) Search by state, then by the name or
the EIN of the employer. The EIN,
name, and the location of the
employer must match.
b) Verify that it is a 501(c)(3) organization

by viewing a '3' listed in column I
If you do not locate the employer under the 2) Select the "Were automatically revoked"
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"Are eligible to receive tax deductible option using the "radio" button on the
charitable contributions" option, web page to determine if the 501(c)(3)
status was revoked.
Note: The "Have filed Form 990-N (e-Postcard)" radio button in Publication 78 should never be
used to determine if an employer qualifies for PSLF.
A2.25 L Direct Loans Only: Employer Not found or Discrepancy found When
Reviewing Directories for Non-Profit 501 (c)(3) Organizations
I KCID,1,01(6) I I
If Then
The organization in question is not found in Recommend the borrower to complete an ECF.Once
either Publication 78 or Business Master File, the ECFis received, the employer will be fully reviewed
so that you are unable to determine if the to determine eligibility.
employer qualifies while you have the caller on
the phone,
A2.26 L Direct Loans Only How to: Review Directories for Private, Non-Profit
Organizations
KC,o,rb)\6)
1
There is no specific directory to determine non-profit status.

If Then
The borrower indicates that his/her Advise the borrower to submit an ECFand the
employer is a private, non-profit employer will be reviewed for eligibility.
organization
A2.27 L Direct Loans Only How to: Handle Requests to Override Judgment of
Denied Employer
I KC10, fbl\6) I
• If the employer or the borrower indicates the employer should be approved after we denied
the ECF,request the borrower or employer to provide any documentation to support his/her
claim.
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o Documentation showing Non-Profit status such as Articles of Incorporation.
o Documentation of the public services provided by the organization.
• When the documentation is received, Compliance will determine if it needs to be escalated to

FSAfor further review.
A2.28 L Direct Loans Only How to: Handle Employer Not Located or Not
Qualified
I KC ID,fb)(6)
If Then
You are unable to locate the employer
You are unable to determine if the Advise the borrower to submit an ECFand the employer
employer qualifies will be reviewed for eligibility.
A2.29 L Direct Loans Only: Call Regarding Ineligible Organization

I KCID: KM1004174
The borrower's employer may call to ask if/why his/her organization is or is not approved.
1) Revie~to determine why the ECFwas denied.
If Then
Denied for being for profit • Advise the borrower that the
organization is for profit and does
not qualify for PSLF.
• If they feel that their organization

is not-for-profit, advise them to
submit proof of not-for-profit
status (e.g. Articles of
Incorporation or approval letter
from IRS showing S01(c)(3)
exempt status).
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Denied for not performing qualifying • Advise the borrower that the
Public Service, organization is not for profit;
however, they do not qualify
because they do not provide a
qualifying public service.
• If they feel that their organization

does provide a qualifying public
service, advise the borrower to
submit proof showing they
provide that specific service and
how it is met.
2) Advise the employer/borrower his/her request will be reviewed.
3) Advise the employer/borrower he/she will receive a call back once the review is complete.
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PART B - LFLS Only: PSLF Employment

Certification Processing Procedure
If necessary, refer to PART A for phone and foundation information. See a lead or supervisor with any
questions.
Summary
Part B contains processing guidance for reviewing and entering information from the borrower's submitted
Employment Certification Form (ECF). The related COMPASS'M screen,fbl( 6l lwas created just for PSLFECF
processing.
When a borrower applies for PSLF,l(bJ(6Jlis used to crea~rds for each ECFthat is sent to FLS.
Additionally, if the borrower's loans are not with FLS,theLJscreen has a field by which FLSrequests the
loans from other servicers.
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Section B1: Pre-Processing

B1.1 Retrieve ECF in FileNet
1) Access the ECFimage through FileNet Imaging.
a) See File Net Imaging procedures for detailed sign in and navigation directions.
b) Select fbl( 5l Wrom

the first drop down menu.
c) Select 'fbl(6l rfrom the second drop down menu.
d) Select the 'Detailed Search' option.
e) Type the oldest processing date in the 'date received' field, based on the daily PSECFVolume
email that is sent.
I) Type '!(bl(BI Inthe~ field.
g) Select 'Search'.
h) Select 'View Item' on the first line that appears to select the oldest task.
2) Using a second File Net session, search the borrower's SSN in both the Processing and Review
queues to work all PSECFsfor a borrower.
a) Verify that the image was logged to the correct SSN by comparing the SSN on the ECFto the
SSN listed in 'lmaging's SSN' field.
b) If the SSN does not match:

i) Change to the borrower's correct SSN in FileNet.
B1.1a Multiple ECFs

If Then
There are documents attached to the ECF • Add the words, 'Logging Error' in the Doc Comment
or will be logged under a different ARC box on the bottom right side of the image
• Send the image to the Review queue by selecting
'Review' in the top right corner of the image
Note: No documents can be processed on~
• Place the document in the 'Review' queue in FileNet .
0 The image will be placed back into WorkFlow to
be completed.
The borrower provides multiple ECFsthat • Enter the information for all ECFsintol(bl(6l I
are included on a single DCN • See Section B2.4 Review PSECFProcessing Macro
The borrower provides multiple ECFsthat Use the same Page 1 for all the ECFsthat were received
are logged on FileNet the same day, and on the same day
Page 1 is only included in one of the ECFs,
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Pages 1 and 2 of the borrower's ECFare • Use the revised Page 2 to approve the ECF
denied, and a revised Page 2 is received o Example:
within 30 days from the stamped date of Page 1 = Doc A
Page 1 from the same employer that Page 2 = Doc B
supports/corrects the reasons for the Page 2a = Doc C
denial o Doc A and Bare received on 08/01/2013 and are

denied on 08/05/2013.
o Doc C is received on 08/20/2013 within 30 days
from the stamped received date of Doc A, is from
the same employer, and corrects the missing
information from Doc B.
o Documents may be pieced together to process
and approve the ECF.
The borrower sends an ECFthat only • Piece the 2 pages together to process as one whole
includes Page 1, and Page 2 is received application, but only if the borrower's name and SSN
within 30 days from the stamp date of appears at the top of Page 2.
Page 1 o Example:
Page 1 = Doc A
Page 2 = Doc B
Page 2a = Doc C
o Doc A is received on 08/01/2013. Doc B is

received on 08/20/2013; Doc A and Doc B can be
pieced together and processed as one whole
application.
o Doc C is received on 08/21/2013. Doc A cannot
be used again to process as another whole
application because Doc A was already used and
approved with Doc B.
The form is illegible and you are unable to • Deny the ECFby leaving all applicable fields from
determine the information on Page 2 of Section 3 and/or Section 4 of the form blank when
the form entering information on ITL2U.
o Place a 'Y' in the Bypass letter field
o Send the Illegible Fax- ECFReceived Letter
■ See Section B2.5 Sending a Manual Denial
Letter.
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B1 .1 b Determine 0MB Approval

1) Verify that the ECFform is Office of Management and Budget (0MB) approved.
a) An OMS-approved form contains the 0MB approval number and the form's expiration date in
the upper right corner of the first page.
If Then
The borrower sends a form that is not the • Deny the request
OMS-approved ECF (contains X's in the 0 See Section B2.4 Review PSECFProcessing Macro
expiration date, and X's in the 0MB code • Indicate in the system that the borrower and the
field at top of form) authorized official did not sign the ECF.
0 Place an 'N' in the "Borrower Signed" field and an
'N' in the (authorized official) "Signed" field.
0 Place a 'Y' in the "Bypass Ltr" field to bypass the
system denial letter.
0 Send the Denied Invalid ECF Not 0MB Armroved
manual denial letter. See Section B2.6 Sending a
Manual Denial Letter
• Comment the employment entry that we are unable
to process an invalid form. See Section B2.7
Commenting on the PSLFScreen {ITL2U)
B1.1c Draft Application for Forgiveness
If you receive the drafted version of the forgiveness application,
• Place the document into the File Net review queue, and
• Send an email to the FLS PSLFSupervisor Review mailbox
o Include the DCN, SSN, and advise that it is the drafted forgiveness form.
B1.2 Review Demographics
B1 .2a FLS Borrower Demographics

1) Compare and review the demographic information (address and phone) on the form when one of
the following is met:
a) The borrower checks the box at the top of the form, indicating that information has changed.
b) The address or phone number on file is invalid.
2) Compare the borrower signed date found on the form to the last date verified (LAST VER) on the
Borrower Demographic screen (TXlJ)
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If Then
1) The account is more recent No changes are necessary
2) The form is more recent • Update demographic information using information

found on the form.
0 When updating the email address, update the
home email. Do not update the contact email.
The email address should be added or updated to
3) The account demographics are invalid the home email address field.
0 Update minor name variations (e.g.
Kim/Kimberly, Mike/Michael)
0 Refer to the Demographics Index for assistance
with making updates.
4) We service a borrower's loan, but the
5
name on the form is different from Send the name discrepancy letter using thefbl( l IARC
the name on file
B1 .2b Non-FLS Borrower Demogrjphicj

1) Add the demographic information to (bJ(Bl See Section B2.4 Review PSECFProcessing Macro
a) If demographic information is missing, sde Section Bl.2c Non-FLS Borrower Missing
Demographics
If Then
The borrower provides a permanent
address and a mailing address on the
form
Add the mailing address to LJ
• Enter this name on fbJ(6J [ See Section Bl.3 Review
NSLDSfor instructions on reviewing NSLDS.
The borrower provides a previous/former 0 Example: Borrower lists Smith as his/her last
name on the ECFand this is the only name with a previous last name of Jones on the
name showing on NSLDSwith no history ECF. If NSLDSlists the borrower's last name as
Jones with no history of Smith, you must use
Jones.
B1 .2c Non-FLS Borrower Missing Demographics

1) If we do not service a borrower's loan, and his/her demographic information is missing, refer to
the table below.
If Then
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• Call the borrower to obtain the information .

0 Call the employer if borrower contact
information is not available
The borrower's name, DOB, or SSN is • Do not call before 8:00 AM or after 9:00 PM (his/her
missing time). Check the borrower's location to determine
his/her time zone.
• Refer to the Time Zone Dialing article in KB for
assistance.
The borrower/employer does not answer

• Leave a message for the intended party with return
contact information.
the phone
• See Section B1.2d ScriQt: Missing DemograQhics
The employer cannot provide SSN due to
Ask the employer to have the borrower contact FLS
privacy issues
Place the image in the review queue in File Net and place
It's determined too late to call the
the entry on hold in COMPASS'Muntil you are able to call
borrower/employer
the next business day.
• Comment the call on ~See Section B2.7
Commenting on the PSLFScreen ~bl(6 l I
• Update the 'PSLF Callback' Macro with:
0 Processor's name
0 Borrower's first name
The missing information is obtained from
0 Borrower's last name
the borrower/employer
0 Date of the outbound call
0 Reason for the outbound call with the DCN
number.
• See Section B2.lh PSLFCallback Macro for
macro instructions
• Comment the call onl(bl(5l 6ee Section B2. 7
Commenting on the PSLFScreenl(bl(6 l I
• Deny the form for the missing information. See
The borrower's name or DOB is not Section B2.4 Review PSECFProcessing Macro.
obtained 0 When denying, do not place an 'N' in the Eligible
Loan field. ~
0 Comment the call on See Section B2.7
Commenting on the PSLFScreen [bl(5l I
• Place the document into the review queue with a
comment stating 'SSN missing, call placed to the
The borrower's SSN is not obtained
borrower. P/PH #'
• No further adjustments can be made without an SSN.
B1 .2d Script: Missing Demographics

1) When leaving a message for a borrower regarding missing demographics, read the script below.
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English Spanish
"Hello, this message is for (Borrower
Name). My name is (Representative
Name} calling from Fedloan Servicing in
regards to an Employment Certification
you recently completed. We are missing
information and need this in order to
review the form. ff you could please return
this call at your earliest convenience, we
would greatly appreciate it. Our number is
1-855-265-4038 and we are open Monday
through Friday,from 8:00 a.m. to 9:00
p.m. Eastern Standard Time. Thank you."
B1.3 Review NSLDS

1) Open NSLDS.See NSLDSTraining Overview to review steps on how to open, log into, and navigate
NSLDS.
2) Review the borrower's loan history on the NSLDSAid tab to determine if the borrower has at least
one eligible Direct Loan with a balance greater than $25.
If Then
• Note all eligible loans (FFELPor DL), including the
Department of Education (DOE) servicer for each
loan.
0 Do not use a servicer code for a commercial
servicer. These types of loans should not be
1) The borrower does have at least one considered for PSLF.
eligible Direct Loan with a balance 0 Select the 'Loan Details' button to bring up either
greater than $25 the student or parent screen, depending on who
is the borrower.
• Review the Direct Loans to determine if the
borrower had more than one prior servicer
• Review all Direct PLUSloans to determine if they are
Direct parent PLUSloans
a) The borrower of the Direct Parent • The Direct parent PLUSloan does not qualify for PSLF
PLUS loan is not the person 0 Example:
employed at the public service • Paul Smith submits an ECF,and NSLDS
organization indicates that the Direct parent PLUSLoan
was taken out by the parent, Jane Smith. Paul
Smith's ECFdoes not prove eligibility for Jane
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Smith's Direct parent PLUS Loan.

• If Jane Smith (the parent borrower) submits
the ECF, then the Direct parent PLUS Loan
may be eligible for PSLFif the borrower
meets the qualifications
2) The borrower does not have any • Deny the request for "no eligible loans" using the
eligible Direct Loans with a balance PSECF Processing Macro.
greater than $25 • See Section B2.1 PSECFProcessing Macro .
• Deny the request for "no eligible loans" using the

PSECF Processing Macro. See Section B2.1 PSECF
Processing Macro
0 Select 'Y' in the "Bypass Ltr" field to bypass the
system denial letter.
0 Send the "Denied Defaulted Loans" manual
3) The borrower's Direct Loans are all
denial letter. See Section B2.5 Sending a Manual
listed as defaulted on NSLDS
Denial Letter
0 Comment the employment entry that all loans on
NSLDS are listed as defaulted and a manual
denial letter was sent. See Section B2.7
Commenting on the PSLFScreen {ITL2U).
0 Archive the form. See Section B2.8 Archive Image
Section B2: Processing the ECF(s)

B2.1 Review the ECF
Determine if all the required fields are populated in Sections 1 through 4 of the ECF.
B2.1 a Sections 1 and 2

1) Section 1: Completed by the borrower.
a) Required information: if missing, deny the request.
i) SSN
ii) DOB
iii) First and Last Name
b) Not required information: if missing, verify/update the demographics on file within
COMPASS'M. Do not deny the request.
i) Borrower address
ii) Borrower phone number
iii) Borrower email address
2) Section 2: Completed by the borrower.
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a) Required: Borrower signature.

i) If the borrower's signature is missing, deny the request. See Section B2.4 Review PSECF
Processing Macro
ii) Refer to AES and FLS- Electronic Signatures: How to Determine Acceptable Types for
guidance on determining if the signature is acceptable to use.
(1) In the 'doc comment' field in workflow, type "DIGITAL SIGNATURE".
(2) Move the image to the review queue in FileNet.
(3) Send an email to the "FLS PSLFSupervisor Review" mailbox.
(a) Subject of the email should be "Digital Signature"
(b) Body should include the borrower's SSN and that the ECFneeds reviewed for
eligibility.
b) Not Required: Signature Date.
i) If the date signed is invalid or missing, enter the File Net Imaging RECEIVEDDATE.
Note: We currently accept 4 versions of the ECF.Two versions have an expiration date of
11/30/2014. This form was released twice. In the first release, the employment dates were
listed as DD-MM-YYYY. In the second release, the employment dates were switched to
MM-DD-YYYY and the language regarding full-time hours not being part of proselytizing
was modified.
Two versions have an expiration of 12/31/2017. This form was released twice. In the first
release, the form contained box 15 in Section 4. In the second release, the box 15 was
removed from Section 4.
B2.1 b Sections 3 and 4

Section Expiration Date Details
Section 3 11/30/2014 Completed by the employer
12/31/2017 Completed by the borrower or

employer
Section 4 Only found on form with Completed by employer

expiration date of 12/31/2017
a) Required Information for Sections 3 and 4 (as applicable):
i) Name of the organization
ii) Employer Identification Number (EIN)
iii) Address of the organization -If only a partial address is listed, this is acceptable. Examples
of a partial address include one or more of the following:
(1) Street address
(2) City
(3) State
(4) Zip Code
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iv) Start date of the borrower's employment
v) End date of the borrower's employment
If Then Action
ECFcertifies that the Do not approve the 1) Deny through COMPASS'Mwith the
entire public service employment. Deny the reason for invalid dates.
employment period request because there is a) To deny the ECF,flip the dates of
occurred prior to the no reason to track employment to show the end
start of the PSLFProgram employment for time date of employment as the begin
(10/1/2007), periods in which date and the begin date as the
payments will not be end date.
reviewed. i) At this time, COMPASS'Mcan
only deny by flipping the
dates
b) This will prompt the system to
deny for the reason of invalid
dates. See Section B2.4 Review
PSECFProcessing Macro
2) Enter all other information provided

in Section 3 on TL2U as it is listed on
the ECF.See Section B2.4 Review
PSECFProcessing Macro.
3) Bypass the system denial letter (see

Process/Update ECF)and send the
"Em~loy'ment Certification Prior to
10/01/2007" manual denial letter.
See Section B2.5 Sending a Manual
Denial Letter.
4) Comment the denial and indicate a

manual denial letter was sent due to
employment was prior to 10/1/2007.
The borrower Check to ensure the ECF 1) If the borrower falls under this
consolidated into a being worked is a new scenario, and the same form was
Direct Consolidation form with employment submitted twice, deny the ECF.
Loan but was previously after the disbursement
2) Deny through the system by placing
denied for not having date of the Direct
'N' in the borrower signed fields.
Direct Loans Consolidation Loan and
not the same form that 3) Enter 'Y' in the 'Bypass Ltr' field to
was previously denied for bypass the system denial letter.
not having Direct Loans.
4) Send the "Consolidated New ECF
Required" manual denial letter.
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Proceed to Section B2.5 Sending a

Manual Denial Letter.
The employment dates Deny the ECF 1) Deny through the system by placing
are before the an 'N' in the eligible loan field.
disbursement date of the 2) Enter 'Y' in the 'Bypass Ltr' field to
first eligible Direct Loan bypass the system denial letter.
3) Send the "Employment Prior to
Disbursement" manual denial letter.
Proceed to Section B2.5 Sending a
i) Employment status: Full-time or part-time status must be checked
ii) Average number of hours per week.
iii) Authorized Official's Name (printed)
iv) Authorized Official's title
v) Authorized Official's signature
(1) Ensure appropriate Human Resources representative signs all ECFsfrom PHEAA
employees.
(a) Only the Senior Vice President of Human Resources is authorized to sign PHEAA
employee ECFs
If Then
ECFis signed Review to see if it is a physical or electronic

signature
Signature is physical Proceed with processing the document
Signature is a font or indicates that is was 1) Deny through the system for the reason
'Electronically Signed' that the borrower signature was missing.
2) Bypass the system letter, and send the

'Digital Signature- Employer' manual
denial letter. See Section B2.4 Review
You are unsure whether the signature is Send an email to the 'FLS PSLFSupervisor
physical or electronic Review' mailbox
• Subject of the email should be

"Electronic Signature"
• Body should include the borrower's
SSN and that the ECFneeds to be
reviewed for eligibility.
vi) Authorized Official's telephone number

vii) Signature date: If missing, deny the request. See Section B2.4 Review PSECFProcessing
Macro
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B2.1c Box 15
1) Box 15: On 2/17/2016, the FSA released an updated PSLFECF.The updated form includes Revised
Pay As You Earn (REPAYE) language as well as the removal of box 15 in Section 4.
If Then
Older form (with box 15) is received with box 15 Deny the form. See step 2) below
not checked, and
• We are unable to approve the request .
The 'unable to obtain certification' box is not • The employer must check box 15 to indicate
that the information in Section 3 is
checked on page one of the ECF.
true/complete.
Older form (with box 15) is received with box 15 • Do not deny the form for box 15 not
not checked, and checked.
• Proceed to Section B2.le Unable to Obtain
The 'unable to obtain certification' box is Certification
checked on page one of the ECF
2) Deny the ECFthrough the system by leaving the following fields blank:
a) Employer name
b) EIN
c) Employment begin date
d) Employment end date
e) Employment Status
f) Hours
g) Authorized Official Name
h) Authorized Official Title
i) Authorized Official Phone number
j) Authorized Official Date signed
3) Place a 'Y' in the "Borrower Signed" field
4) Place a 'N' in the following fields:
a) "Address Prvd" field
b) "Authorized Official Signed" field
c) "Acceptable" field
d) "Employer Approved" field
5) Enter 'Y' in the "Bypass Ltr" field to bypass the system denial letter.
6) Send the "Denied - Box 15 Not Checked" manual denial letter. Proceed to Section B2.5 Sending a
7) Comment the denial and indicate a manual denial letter was sent due to box 15 was not checked.
If Then
1) An ECFwas previously denied for box 15 not Check to see if the Authorized Official initialed
checked, and the same ECFis returned with the change
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box 15 now checked
2) Box 15 is now checked, and the Authorized Approve the ECF

Official initialed the change
3) Box 15 is now checked, but the change was Call the Authorized Official to verify that all
not initialed by the Authorized Official information in Section 3 is true
a) Contact is made with the Authorized Comment the information to the account.
Official Proceed with processing the document.
b) No contact is made with the Authorized • Deny the ECFthrough the system by leaving
Official the following fields blank:
0 Employer name
0 EIN
0 Employment begin date
0 Employment end date
0 Employment Status
0 Hours
• Comment the phone call and denial. Indicate
the ECFwas denied because box 15 was
checked, but the change was not initialed by
the Authorized Official.
4) The borrower alters information in Section As long as this is the first time we received this
3 and initials the change ECF, box 15 is checked, and Section 4 was
signed by an Authorized Official, approve the
ECF.
B2.1 d Additional Fields

1) Type of Public Service Organization
a) Form expiration date of 11/30/2014: one of the first three boxes (a - c) should be checked.
i) If box c is checked, one or more types of public service must be checked.
b) Form expiration date 12/31/2017: Questions 9-11 need to be answered yes or no.
If Then
ALL three questions (9-11) are answered 'No' • The borrower and official are certifying
that the employer is indeed for-profit.
• Deny these without escalating through the
Employer Database by placing an 'N' in the
'Employer Approved' field.
All three questions are not answered 'No' • The employer should still be reviewed
following normal procedures.
• See Section B2.2 Review the EmQloyer
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Website/Di rectory.
c) Questions 12 or 13
If Then
Questions 12 or 13 on the new ECFwith an • The borrower and official are certifying the
expiration date of 12/31/2017 are answered organization does not qualify.
"Yes" • Deny these without escalating through the
Employer Database by placing an 'N' in the
'Employer Approved' field.
Any information is altered The borrower or employer, as appropriate,

must initial next to the change.
Information is altered and no initials are Call the borrower or employer, as
present appropriate, directly to obtain the conflicting
or altered information.
B2.1 e Unable to Obtain Certification

If Then
1) The borrower checked the box indicating • Perform a Google search to verify if the place of
unable to obtain certification employment is currently operational.
0 Open Internet Explorer and type organization's
name into Google and press ENTER.
0 Click on organization's website.
0 Place a call to the organization using the
"Contact Us" phone number located on their
website.
a) Organization is still operational • Deny through COMPASS'Mfor the reason that the
certification sections were not completed. Leave
all COMPASS'Mfields in the certification section
blank. See Section B2.4 Review PSECFProcessing
Macro
• Bypass the system denial letter and send the
"lncomQlete or Missing Certification" manual
denial letter. See Section B2.5 Sending a Manual
Denial Letter.
b) Organization is closed Review the ECFto see if additional documentation was

provided.
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i) Organization is closed, and • Email the "FLS PSLFSupervisor Review" mailbox.

additional documentation was 0 Include all attachments in the email.
provided
ii) Organization is closed, and • Call the borrower and request he/she send in
additional documentation was documentation such as:
NOT provided 0 W-2s for time periods employed (Required)
0 Paystubs
0 Any other documentation that would support
his/her request.
• Bypass the denial letter. Send the "Unable to
Obtain Certification" manual denial letter.
c) Google search does not yield results • Send an email to the FLS PSLFSupervisor Review
for the employer in box for a determination.
• A Lead and/or Compliance will review the
documentation to determine if it is sufficient to
approve the organization as a qualifying employer.
d) A Lead and/or Compliance • Use the information listed in the email to approve
determines the organization can be the ECF.
approved • See Section B2.4 Review PSECFProcessing Macro
e) A Lead and/or Compliance • The email will advise what actions are needed .
determines the information is not • Deny the ECFfor the missing information in
sufficient Sections 3 and 4 if the ECFwith an expiration date
of 12/31/2017 is received
2) The borrower has been denied • Send an email to the FLS PSLFSupervisor Review
previously and is now escalating due to mailbox to have the ECF reviewed by Compliance.
the employer refusing to complete the Note that Compliance will only review the ECF if
form the documentation is attached (e.g, a W-2 form).
• Documentation must be requested if it is not
already provided.
B2.1 f Missing/Conflicting Information

1) Call the employer directly to obtain information if any of the following information is missing or
conflicting from Section 3 or 4 of the ECF:
a) Name of the organization
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b) EIN
c) Address of the organization
i) If only a partial address is listed, this is acceptable. Examples of a partial address include
one or more of the following:
(1) Street address
(2) City
(3) State
(4) Zip Code
ii) If they do not provide any information in this field, a call must be made.
d) Start date of the borrower's employment
e) End date of the borrower's employment
f) Employment status
g) Average number of hours per week
h) Authorized Official's name
i) Authorized Official's title
If Then
1) The Authorized Official's telephone • Call the borrower to obtain the

number is missing telephone number so that the
Authorized Official may be contacted.
2) The new ECFreceived conflicts (EIN, dates • Call the employer to verify the correct
of employment, hours or status) with an dates, hours and status
ECFrecord already approved for the 0 Do not call before 8:00 AM or after
borrower for the same employer 9:00 PM (his/her time). Check the
borrower's location to determine
his/her time zone.
0 Refer to the Time Zone Dialing article
in KB for assistance.
• Use the obtained information to process
the request.
• Comment the outbound call.
0 If we have loans for the borrower,
comment the call through ATC00.
0 If the borrower is not on our system,
comment the call on ITL2U.
a) The employer does not answer • Leave a message for the intended party
with return contact information.
0 See Section B2.lg ScriQt: Missing ECF
Information for a scripted message.
• Update the 'PSLF Callback' Macro with
processor's name, the borrower's first
name, borrower's last name, borrower's
SSN, Employer name, Authorized
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official's name, date of the outbound call

and reason for the outbound call.
0 See Section B2.lh PSLF Callback
Macro for macro instructions.
• Deny the ECFthrough the system. This
generates a denial letter that includes a
new ECF.
0 The missing information is listed and
the letter explains the steps the
borrower may take to have the ECF
reconsidered.
Place the image in the review queue in
b) It's determined too late to call the FileNet and place the entry on hold in
borrower/employer COMPASS'Muntil you are able to call the next
business day.
• Deny through COMPASS'Mfor the reason
that the certification sections were not
completed. Leave all the fields in the
3) The employer is requesting us to access certification section blank. See Section
the borrower's verification of employment B2.4 Review PSECFProcessing Macro
from another source (such as a website).
• Bypass the denial letter. Send the "Unable
to Obtain Certification" manual denial
letter.
Note: When the employer or borrower calls with the requested information, the phone
representative updates the 'PSLF Callback' Macro outbound call tracking spreadsheet and
submits a request to have the ECF processed.
If we have loans for the borrower, the phone representative submits an RVECFtask.
If the borrower is not on our system, the phone representative emails the SSN and information
to the "FLS PSLFSupervisor Review" mailbox to have the ECFprocessed.
B2.1g Script: Missing ECF Information

1) When leaving a message for a borrower regarding missing information, read the script below.
English Spanish
(b)(6)
Conf1dent1al Page I 85
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B2.1 h PSLF Callback Macro

1) When the employer or borrower calls with requested information, the phone representative
updates the 'PSLF Callback Macro' and submits a request to have the ECF processed.
2) If further contact with the employer or borrower is made, the PSLFCallback Macro will need
updated with the missing or correct information. See the below table for a list of possible
scenarios:
If Then Action
You contact the Submit the 1) Access the MACRO through LAUNCH PAD on your
employer to information to the desktop.
obtain missing PSLFCallback Macro
information
You contact the 2) Expand the 'Processing Tools' option.
employer to verify
conflicting
information
You contact the 3) Select 'PSLF Callback.' The Macro will open through
borrower to the main screen.
obtain missing 4) Enter the following:
demographic a) Borrower SSN
information b) DCN ( Document Control Number)
c) Borrower First Name
d) Borrower Last Name
e) Employer Name
I) Official Name
Note: If any information is missing, leave the field blank
5) Select check boxes for missing information
a) Example: If you call to obtain the EIN and Official
Title, check the corresponding boxes
6) Press the Insert button
7) A pop-up box will appear. Click 'OK.'
8) Click 'Reset' at the bottom of the Macro
9) Comment the account that you made the outbound

call to obtain the missing information.
a) See Section B2.7 Commenting on the PSLFScreen
{ITL2U)
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B2.1 i Requests to Override Judgment of a Denied Employer

If Then
The employer or the borrower requests • The borrower or employer must provide a
reconsideration of its organization/employer request and appropriate documentation in
after an ECFwas denied. writing to support the employer's qualifying
status
0 Examples of acceptable documentation
include:
• Proof of employer's not-for-profit
status from federal or state
government or regulatory/taxing
body;
• Articles of incorporation/charter; or
• Implementing legislation .
Additional information is provided • Email the documentation to the "FLS PSLF

Supervisor Review" mailbox.
• Include "PSLF Employer Review" in the
subject line.
0 Note: The request is then forwarded to
Compliance for review. Compliance will
escalate to FSA, if necessary.
• Place task in a 'Review' status, pending the
outcome of Compliance's review. You will be
notified by email on how to proceed once
the review is completed. See Section B2.3
ECFReguires Further Review.
1) Complete the request based on outcome of Supervisor/Compliance/FSA review.

If Then
1) Compliance/FSA's review approves • Correct the current ECFrecord to reflect a

employer's PSLFeligibility 'Y' in employer approved field. See
Process/Update ECF.
• I
Document l(bl(5l comment screen with the
details of the determination and that
approval has been provided by Compliance
or FSA,as applicable.
• Approve the ECFform and the system will
generate the approval letter to the
borrower. See Section B2.4 Review PSECF
Processing Macro
2) Compliance/FSA's review denies employer's • Comment the account with the denial
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PSLFeligibility reason and a detailed comment as to why

the employer is still denied.
• Contact the borrower by phone to advise
the override request is denied and give the
reason provided by Compliance/FSA.
a) Unable to contact the borrower by • Request a special letter to provide

phone information regarding the denial.
0 For FLS borrowers, submit the PSDNL
I
l(bJ(6Jin J(bJ(6J I
0 For non-FLS borrowers, send an email to
the "FLS PSLFSupervisor Review"
mailbox.
B2.1j Attached Certification

If Then
The ECF is not completed and the employer • Deny through COMPASS'Mwith the reason that
attached the certification the certification sections were not completed.
• Leave all the COMPASS'Mfields in the
certification section blank.
• Bypass the system denial letter, and send the
"Attached Certification - Action Required"
• See Section B2.5 Sending a Manual Denial
Letter
Section 4 of the ECFis signed and completed by • Call the employer to attempt to obtain the
an authorized official but Section 3 has missing missing documentation. Refer to Section B2.lf
information that he/she attempted to provide in Missing/Conflicting Information for additional
guidance
the attached documentation
• The attempt to obtain missing information • Deny through COMPASS'Mwith the reason that
is unsuccessful the certification sections were not completed.
See Section B2.5 Sending A Manual Denial
Letter.
• Deny only for the missing information that was
not provided but attached in a separate
document.
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B2.1 k ECF Retraction

If Then Action
Any time an ECFrecord The adjustment must not • Send the account to the FLS PSLF
with an approved status be made at this time Supervisor Review mailbox for review
needs to be changed to a without prior approval with the subject line, "PSLF Retraction
Request."
denied status
• Include the account number or SSN in
the body of the email with the form
sequence number that needs to be
reviewed.
The status needs changed The adjustment will be • Deny the request by placing an 'N' in the
after review made by the 'Employer Approved' field and a 'Y' in
representative working the the 'Bypass Letter' field.
email • Populate the PSDNLARC requesting the
specialized denial letter.
B2.11 Escalated Situation: ECF Was Denied

If Then
Processing a request from a borrower who • Send an email to the "FLS PSLFSupervisor
has escalated because his/her ECFwith Review" mailbox. Include all attachments in
attached certification was denied the email by exporting the images.
• Refer to File Net Imaging procedures .
B2.1 m Escalated Situation: Self-Certified

1) Review the account to determine if the borrower is escalating his/her request.
a) If not, deny the request.
i) Deny through COMPASS'Mwith the reason that the authorized official is not acceptable to
certify. See Section B2.5 Sending A Manual Denial Letter.
(1) Enter 'Y' in the employer "Signed" COMPASS'Mfield.
(2) Enter 'N' in the employer "Acceptable" COMPASS'Mfield. The system will generate a
denial letter to the borrower indicating the authorized official is not eligible to certify.
If Then
The borrower indicates that he/she is the • FLSwill consider his/her request pending
sole owner/operator of his/her organization receipt of supporting documentation.
and there is nobody available to certify • Email borrower's requests to the "FLS PSLF
his/her form Supervisor Review" mailbox. These will be
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considered on a case-by-case basis.

o Include all supporting documents in the
email. The supporting documentation must
include:
• W-2 (Required)
■ Paystubs
■ Proof of not for profit status
B2.2 Review the Employer Website/Directory

The PSLFDatabase contains a list of employers who have been escalated for further review. If unable
to determine if an employer qualifies for PSLF,the record must be added to the database.
1) Open Employer Database

a) Access the MACRO through the LAUNCH PAD located on your desktop
b) Once the Launch Pad has open, expand the "Processing Tools" option
c) Select "PSLF Organization Database" option
2) Search for the organization on the ECFusing the search feature on the database.
a) Click Clear Filter, located at the bottom of the database, to ensure the entire database is
searched.
b) Select 'EIN Filter.'
c) Enter the EIN in the 'Search' field, and press 'OK.'
d) Press the Clear Filters button, and delete the previous information in the Search field if
performing multiple searches.
e) Select the view details button to view the details regarding the status of this employer
Note: Many government agencies use the same EIN but are not affiliated with one another.
If Then
The organization is operated as government • Approve the organization as 'GO'

but is listed under a different name and same (Government Organization)
EIN 0 Example: The employer on the ECFhas
an EIN of 586000134. A search for the
EIN shows the database already lists the
organization for this EIN.
0 The View Details window indicates that
the employer associated with the EIN, is
approved as a government
organization.
The organization (with same name, location, Continue with processing the ECF.It is not
and EIN) has already been approved or necessary to review the employer's eligibility
denied, and no additional documentation was again.
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I provided within the previous year
f) If the organization (with same name, location, and EIN) has a status of inconclusive, proceed to
the chart below
If Then
We received W-2s or proof of the • Comment the DCN of the correspondence

organization's non-profit status in the New Comment section of the
employer entry.
• Send a screen shot of the Database entry to
the FLS PSLFSupervisor Review mailbox to
have it further reviewed.
0 Include all attachments in the email by
exporting the images. If additional
information is needed, the email will
be responded to.
• Once a decision is made, the entry will be
returned in the database. Process the ECF
according to the guidance provided. See
Section B2.4 Review PSECFProcessing
Macro
The employer is approved for a certain • Add two separate records .

timeframe but denied for another 0 One record for the approved
timeframe, the other for the denied
timeframe.
• Comment the account thoroughly if a new
ECF is received for the same employer, but
for a different borrower, and no additional
documentation is received.
The employer must be denied • Follow the guidance placed in the comment
history of the database on how to deny the
borrower on □
o If a manua e er is required, send an
email to the FLS PSLFSupervisor
Review mailbox to have a manual letter
drafted. Include a screen shot of the
database entry for the organization.
We receive a new ECFfor the same • Follow the guidance placed in the comment
borrower/employer with different dates of history of the database on how to deny the
employment and no additional borrower on~
documentation • Send an email to the FLS PSLFSupervisor
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Review mailbox to have a manual letter

drafted.
o Include a screen shot of the database
entry for the organization.
g) If the organization is in an inconclusive status because Compliance is able to approve the

organization in part (example: The organization gained or lost their 501(c)(3) status, so not all
employment can be approved),
i) Review the comments to see if the dates provided coincided with the dates listed on the
ECF being worked.
If Then
The dates coincide • Add two separate records .

0 One record for the approved
timeframe, the other for the denied
time frame.
• Comment the account thoroughly with
the guidance provided. See Section B2.4
Review PSECFProcessing Macro
The dates do not coincide • Comment the DCN in the New

Comment section of the database.
• Once a decision is made, the entry will
be returned in the database. Process
the ECF according to the guidance
provided. See Section B2.4 Review
h) If the employer is listed as an approved non-for-profit organization, review the date which the
employer was approved.
If Then
The approved date is within one year from Approve the ECF based on the current
the date the new ECF is received approval in the database.
The approved date was greater than one year • Populate the PSNPR ARC through~
from the date the new ECF is received for employer review to ensure th
maintained their not-for-profit status with
the IRS.
• The PSNPR ARC will be worked by one of
the PSLF Leads to verify the employer still
has their not-for-profit status
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The employer still qualifies The Lead will update the approved date in the
database. Proceed with processing the ECF
The employer is no longer approved • The Lead will update the database to
reflect the emolover is denied, update the
b)(6)
ECF record or o reflect a denied
status, and have ",e uorrower contacted.
• Once a decision is made, the entry will be
returned in the database. Process the ECF
according to the guidance provided. See
Section B2.4 Review PSECFProcessing
Macro.
B2.2a Employer Match Not Found

1) If an exact employer match is not found in the Employer Database, determine if the organization is
affiliated with religion.
a) Review Section 3 of the ECFto see if website is listed.
If Then
The website is provided • Place the website into the address bar and
press ENTER.
• Continue to step b) .
The website is not provided • Open Windows Explorer and perform a

Google search for the organization's name.
b) Click on the organization's website.

i) View the pages for religious content under "About Us" and "Our Mission" sections to
determine if the employer is affiliated with religion.
If And Then
1) The organization is N/A Processing of the ECF request will

affiliated with be based on the version that was
religion received.
a) The employer is N/A Check if the employer qualifies as

affiliated with 50l(c)(3).
religion and the The employer • Deny the request and advise the
borrower qualifies as 50l(c)(3), borrower to send in a new ECF.
submitted an • Place a 'Y' in the Bypass letter
old version of field.
the ECF • Send the "Denied EmQloy'ed by
(DD/MM/YYYY) Religious Org" manual denial
letter. See Section B2.4 Review
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PSECFProcessing Macro.
You are unable to Add the employer to the Employer

determine if the Database for
employer qualifies as Supervisor /Comp Iia n ce/Federa I
501(c)(3) Student Aid (FSA) review.
It is determined that Deny the ECFusing the same
the employer method based on the religion-
qualifies related employer qualifying as a
not-for-profit.
It is determined that Deny the ECFin the system as
the employer does employer not approved.
not qualify
b) The employer is N/A Check if the employer qualifies as
affiliated with 501(c)(3).
religion and the
The employer Approve the ECF
borrower qualifies as 501(c)(3)
submitted a You are unable to Add the employer to the Employer
newer version determine if the Database for
of the ECF employer qualifies as Supervisor /Comp Iia n ce/Federa I
(MM/DD/YYYY) 501(c)(3) Student Aid (FSA) review.
2) It is determined N/A • Review to see what type of
that the employer public service box is checked.
is not affiliated with • Begin your search with one of
religion the corresponding websites for
that type of public service.
0 Use Section B2.2c below to
locate the website.
3) No box is checked N/A • Use Sections B2.2b - d below to

or the incorrect box determine the correct type of
is checked public service.
B2.2b Government Organizations

1) Access www.usa.gov/agencies for Federal, State, Local or Tribal government organizations,
agencies, or entities
2) Select the appropriate link ("State Government," "Local Government" or "Tribal Government") to
access the website for each state, local or tribal.
a) State government.
i) Click state from the list.
ii) Locate the department in which the agency would be located.
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iii) Perform a search for the agency.

If Then
1) The name of the agency, and if any part • The organization can be approved with
of the address provided match, "GO" code.
2) Unable to locate the employer • Perform a Google search for the
organizations website.
3) The domain for the government • The employer is approved, including the
organization, agency, or entity is .gov or following:
.mil 0 Public Schools
0 Public School Districts
0 Public Libraries
0 Military Branch (Army, Navy, Air
Force, Marines, Coast Guard, State
National Guard)
4) You are uncertain whether the • Add the organization to the Employer
employer should be approved Database for further review.
iv) When reviewing an employer that may be government, it cannot be approved just because
it appears on a state website.
(1) The employer would need to be organized under statute or be a political subdivision,
etc. in order to be approved under government.
b) Note: Employers listed on government websites that are typically not governmental entities
are nursing homes and daycare centers. Nursing homes and daycare centers often appear on a
state website because they are licensed by the state, not because they are governmental
organizations. In many instances, daycare centers and nursing homes are for-profit and not
governmental.
3) Access National Center for Education Statistics website: http://nces.ed.gov/globallocator / to
confirm public schools, universities, and school districts, libraries.
a) Perform a search using the school information on the ECF.
If Then
Click on the name of the school to review the

The name of the school is listed
details.
Do not approve as government. Proceed to
The school is listed as a private non-profit review the organization as a non-profit
501(c)(3) using the IRS Business Master File
(BMF) found on the IRSwebsite at
https://www.irs.gov/Charities-&-Non-Profits.
b) All Charter Schools must be reviewed by Compliance for approval.
i) If the School Directory search indicates the school type is "Charter," add the employer to
the Employer Database for further review.
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4) Access http://nces.ed.gov/globallocator/ to confirm a Tribal college or university.

5) Add the employer to the Employer Database to be further reviewed if the above resources are
unable to confirm an employer qualifies for PSLFeligibility.
6) Note: Although the U.S. Congress (U.S. Senate or House of Representatives) qualifies as a
government organization, members of the U.S. Congress (Senator or Representative) do not
qualify for PSLF.Congressional staff members and state legislators (and their staff) may qualify,
except for any period of time that they work for a political campaign (for that timeframe, the
staffer ceases to be a government employee and is considered to be working on behalf of a
partisan political organization).
a) Email the account information if an ECFfor an employer affiliated with the U.S. Congress is
received to the "FLS PSLFSupervisor Review" mailbox for further review. Place the task on
hold until guidance is provided.
B2.2c Non-Profit 501 (c)(3) Organizations

1) See Section A2.24 FLSOnly How to: Review Directories for Non-Profit 501(c)(3) Organizations for
guidance on the following:
a) How to review Non-Profit 501(c)(3) Organizations.
b) If an employer is not found or if there is a discrepancy when reviewing the directories.
If Then
An organization has multiple locations across You may need to download the BMF for the
several states state where the corporate office is located.
You cannot locate the organization using any of Proceed to private, non-profit organizations
the Non Profit websites providing public services.
B2.2d Private, Non-Profit Organizations Providing Public Services

1) Perform one final review to ensure that the organization cannot be approved as government or
501(c)(3).
a) See Section A2.26 FLSOnly How to: Review Directories for Private, Non-Profit Organizations
for guidance.
Note: Any ECFthat indicates employment with an American Civil Liberties Union-related
organization (e.g. foundation, union fund, ACLU of VT, etc.) must be placed in the employer
database for review by our Compliance department.
B2.2e Escalate Non-Approved (Not Listed) Employers

If Then
Unable to locate the organization in one of the • Add the employer to the Employer Database
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directories for Supervisor/Compliance/FSA review.

• Place the ECF in a hold status on TL2U. See
Section B2.3 ECF Requires Further Review
• Comment the account. See Section B2.7
5
Commenting on the PSLFScreenfbl( l
• Select "Add New Org."
1) Use the ECFform to enter the fields below in the pop-up window:
a) Select your P or PH# from the drop down box.
b) SSN
c) Public Service Organization
d) EIN
e) Website Address (If provided or located)
f) City (If provided or located)
g) State (If provided or located)
h) Comment section: Include details regarding the reason for review.
2) Select "Save Changes."
3) Check the Employer Database daily to process completed reviews.
a) Open the Employer Database.
b) Click "Review Pending/Hold."
c) Work all entries in a "P" status in the ECFstatus column next to the corresponding P or PH
number.
d) Select the "View Detail" button on the employer entry
e) View the 'Comment History' to determine what action(s) need to be taken.
f) All records that have not been completed display with the processor's name. The status of the
record will be displayed in the "Status" column. A record under review will reflect one of the
following statuses:
Status ECFStatus
Approved, Approved Religious, Denied, Pending
Inconclusive
Review Hold
i) Process all records that are "pending," which means the employer has been approved or
denied. See Section B2.4 Review PSECFProcessing Macro.
i) Select the Make Edits button at the top right.
ii) Change the "ECF Status" from "pending" to "completed" by selecting "completed" in the
"ECF Status" dropdown box in the Employer Database once the record has been added to
TL2U.
iii) Select the current date (today's date) from the calendar drop down box.
iv) Select "Save," to keep the edits made to the record.
Note: ECFswith a "completed" status will no longer appear when "Review My Entries" is
selected.
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Note: A record that is on "hold" is still under review.
B2.3 ECF Requires Further Review

1) If the ECFrequires further review, follow the steps below.
a) Enter the reason for review and your PH# in the Doc Comments field in FileNet Imaging.
b) Place the ECFinto a 'Review' status on TL2U. See Section B2.4 Review PSECFProcessing Macro
i) Enter an 'R' in the 'Hold/Review' field.
ii) Enter all applicable information.
iii) Press F6 to accept the entry.
iv) The system will send a letter to the borrower advising FLSis currently reviewing his/her
(1) The letter will advise that we will be in contact with them once the review is
completed. The status of the form will reflect 'Review.'
c) Add the employer to the database for review.
2) Complete the request based on the Supervisor/Compliance/FSA review in the database.
a) Access the Image from the Review Queue:
i) Select 'Workflow' from the first drop down menu.
ii) Select 'FLS Servicing Review' from the second drop down menu.
iii) Enter the SSN in the 'Account Number or SSN' field.
iv) Select Search.
v) Select 'View Item' on the first line
If Then
• Comment TL2U with the details of the

determination and that approval was
provided by Supervisor/Compliance/FSA.
See Section B2.4 Review PSECF
Approved by a Supervisor/Compliance/FSA Processing Macro
• Approve the employer. See Section B2.4
0 The system will generate the
approval letter to the borrower.
• Comment TL2U with the details of the

determination and that Compliance/FSA
provided a denial. See Section B2.4
Denied by Compliance or FSA • Update the current TL2U record .
• Change the Hold/Review field from 'R' to
'N' and deny the employer. See Section
B2.4 Review PSECFProcessing Macro
0 The system will generate the denial
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letter with the reason that the

employer does not qualify.
B2.4 Review PSECF Processing Macro

1) Access the MACRO through the LAUNCH PAD located on your desktop
a) Expand the 'Processing Tools' option
b) Select the 'PSECFProcessing' option
i) The PSECFProcessing box will open, and the HERA session will change to the WAPC Launch
Pad version
2) Enter the borrower's SSN in the 'SSN' field.
3) Select 'Load Acct'

a) If the borrower has previously submitted an ECFor FLS is servicing loans for the borrower, the
borrower's demographic information will auto populate in the macro.
b) Make any necessary changes to the borrower demographics based on the new ECF.
i) Name (First, middle initial, and last name)
If And Then
The borrower provides a Per review of NSLDS,the Do not add the middle initial
middle initial on the ECF middle initial is not listed and to the macro
does not show in history
The borrower does not Per review of NSLDS, a middle Do add the middle initial to
provide a middle initial initial is listed the macro
ii) Address
iii) DOB
iv) City
v) State
vi) Zip
vii) Domestic Home Phone
viii) Domestic Alternate Phone
ix) Email
c) Select 'Eligible Lns' from the drop down if the borrower has eligible loans for PSLF.
Note: If you select 'N,' the entire right side of the processing application will be greyed out and
not editable.
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d) Select 'Brwr Signed' from the drop down if the borrower has signed the ECF.
e) Select the date the borrower signed the form (if applicable) in the 'Date Signed' field from the
calendar.
f) If you selected that the borrower does not have eligible loans,
i) Ensure that all information in the macro is accurate based on the ECFreceived.
ii) Click the 'Submit ECF' option on the macro to deny the ECFfor no eligible loans.
(1) A message indicating that the request was denied and a letter was sent will appear.
iii) Click 'OK,' to clear all fields within the macro.
iv) Archive the ECFand move to the next ECFto be processed from Workflow.
g) Check the corresponding box if the borrower is being denied for one of the following:
i) Employment Prior to 10/1/2007 (Emp Prior to 10/1/07)

ii) Box 15 Not Checked (Box 15)
iii) Employment Prior to Consolidation (Emp Prior to Consolidation)
iv) Employment Prior to Disbursement (Emp Prior to Disbursement)
v) Boxes 9, 10, & 11 Checked No (Boxes 9, 10 & 11)
If Then
• Ensure all information in the macro is true and accurate based

on the ECFreceived.
• Click the 'Submit ECF' option on the macro to deny the ECFfor
Box 15 not checked.
0 A message indicating that the request was denied and a
'Box 15' is selected as the letter was bypassed will appear.
denial reason • Click 'OK' to clear all fields within the macro
0 Note: You will still need to manually send the denial letter
for Box 15 Not Checked, but the macro will automatically
comment the account.
• Archive the ECFand move to the next ECFto be processed from
Workflow.
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• Enter the name of the employer in the Employer Name Field

0 If the complete name of the employer will not fit in the field,
abbreviate the employer's name and notate the complete
name in the comment section of TL2U.
• Switch the begin and end dates when entering them in the
macro.
0 Example: The borrower's employment begin date is
4/14/2005 and the end date of employment is 10/25/2006.
Since both the employment begin and end dates are prior to
October 1, 2007, the date 10/25/2006 should be entered in
the employment begin date field and 4/14/2005 should be
'Emp Prior to 10/1/07,' entered into the employment end date on the macro.
'Emp Prior to 0 Entering the employment begin and end dates backwards
Consolidation,' or 'Emp will cause the system to deny the ECFfor invalid
Prior to Disbursement' is employment dates.
selected as the denial
• Note: Backwards dates will not appear in the denial
letter that goes to the borrower because the processor
reason
will bypass the system letter and send the manual letter.
• Ensure all information in the macro is accurate based on the ECF
received.
Emp prior to 10/1/07, Emp Prior to Consolidation, or Emp Prior
to Disbursement.
0 A message indicating that the request was denied and a
letter was bypassed will appear.
• Click 'OK' to clear all fields within the macro .
0 Note: You will still need to manually send the denial letter,
but the macro will automatically comment the account.
Workflow.
• Enter the name of the employer in the Employer Name field
• Ensure all information in the macro is true and accurate based
on the ECFreceived.
'Boxes 9, 10, & 11' is

Boxes 9, 10, & 11 Checked No.
selected as the denial 0 A message indicating that the request was denied and a
reason letter was sent will appear.
• Click 'OK' to clear all fields within the macro
0 Note: The macro will automatically comment the account.
Workflow.
h) Enter the EIN provided on the form in the 'EIN' field.
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Note: If items i) through z) are missing, and the employer could not be reached to obtain the
information, leave those fields blank.
i) The 'Employer Approved' field automatically defaults to 'Y.'

j) Select the begin date from the calendar in the 'Employment Begin Date' field.
i) Example: If the date of employment is 1/1/2012:
(1) Click on the Month and Year at the top
(2) Click on the year at the top
(3) Click on the year needed
(4) Click on the month needed.
(5) Click on the date needed. Once the day is selected, the calendar will close and the date
will automatically populate into the macro.
k) Select the end date from the calendar in the 'Employment End Date' field.
I) Enter the hours worked per week in the 'Hours' field.
m) Select either 'F' for full-time, or 'P' for part-time, from the drop down box in the 'Status' field.
n) Select one of the following codes from the drop down box in the 'Type of Service' field:
b)(6) Government AmeriCorps
Government
Government Peace Corps
Non-profit 501(c)(3) organization
Private, non-profit organization

,, ~~ ect the applicable code in the 'Type of Non-Profit' field if PR is selected as the type of
organization from the drop down box.
Note: If PR is not selected as the type of organization, this field will not appear.
b)(6)
EARLYCHILDHOOD ED
PUBLICEDUCATION
EMERGENCYMANAGEMENT
LAW ENFORCEMENT
MILITARY SERVICE
0TH ERSCHL SERV
DISABILITIES/ELDERLY
PUBLICHEALTH
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(b)(6)
PUB INT LAW SERVICES
PUB LIBRARYSERV
PUBLICSAFETY
SCHLLIBRARYSERV
o) Select 'Y' or 'N' from the drop down box 1nthe 'Address Prvd' field to 1nd1cate1fthe employer
provided their address. 'Y' should be selected if only part of the address is provided.
p) Enter the name of the authorized official in the 'Official Name' field.
q) Enter the title of the authorized official in the 'Official Title' field.
r) Select 'Y' or 'N' from the drop down box in the 'Official Signed' field to indicate the authorized
official signed the form.
s) Select 'Y' or 'N' from the drop down box in the 'Sign Acceptable' field to indicate if the
authorized official signature is acceptable.
i) This field should always be populated 'Y' unless the borrower self-certified the ECFor you
are directed by a Supervisor or Compliance.
t) Enter the date the authorized official signed the form in the 'Official Date Signed' field.
u) Enter the phone number of the authorized official in the 'Official Phone Number' field.
v) Populate the 'Serviced At' field with the servicer code (below) to ensure the borrower's loans
are transferred to FLSif the borrower has PSLF-eligible loans with another servicer.
Code Servicer
(b)(6)
ED FINANCIAL
GLHEC
UHEAA
ASPIRE
MOHELA
NELNET
OSLA
GRANITESTATE
NAVIENT (formerly Sallie Mae)
SPLITSERVICER(MORE THAN ONE DOE SERVICER)
ONLY FEDLOANOR BORROWERHAS0 DIRECTLOANS
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i) Note: If 'SS' is entered, FLSwill contact all of the borrower's servicers to request a transfer
of his/her loans.
w) Enter 'Y' or 'N' in the 'Prior SRV' field if there has ever been a Prior Servicer. This field is only
required if the ECFis approved and the borrower has loans with another servicer.
x) 'Bypass Ltr' field defaults to 'N.' Change the indicator to 'Y' in the instance you need to prevent
a system denial letter from being sent. Complete this by using the drop-down box.
i) Bypassing the system letter will result in a manual letter needing to be sent.
y) Enter the employer's foreign phone number ('Official Foreign Phone' field) found in the
'Authorized Official's Telephone' field on the ECF
B2.5 Sending a Manual Denial Letter

1) Note: When sending a manual letter to a borrower, do not use the SSN. Use the borrower's
account number. If the borrower does not have an account with FLS,label the document with the
first and last name of the borrower.
2) To deny a request for a reason not included in the system-generated denials,
a) Enter 'Y' in the BYPASSLTRfield.
b) Locate the letter in the Related Letters or Related Forms table.
c) Send a manual denial letter when you encounter the following scenarios·
If Then
The borrower's ECFis illegible and you are Send the "Illegible Fax - ECFReceived Letter"
unable to determine the information on manual denial letter.
page 2 of the form
The borrower's Direct Loans show as • Deny the request through the system with
defaulted on NSLDS the denial reason that the borrower's loans
do not qualify.
• Send the "Denied Defaulted Loans" manual
denial letter.
The form is not 0MB approved • Deny through the system with the denial
reasons that the ECFwas not signed by the
borrower and employer.
• Place an 'N' in the borrower signed and
employer signed fields.
• Send the "Denied - Invalid ECFNot 0MB
AQQroved" manual denial letter.
The new form with an expiration date of • Do not approve the request. The employer
12/31/2017 is received, and box 15 in must check this box to indicate that the
section 4 is not checked information in Section 3 is true/complete.
• Send the "Denied - Box 15 Not Checked"
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The borrower was denied for not having Send the "Consolidated - New ECF Reguired"
Direct Loans, consolidated his/her ineligible manual denial letter.
loans into a Direct Consolidation Loan, and
submitted the same form that was
previously denied for not having Direct
Loans
The employer is affiliated with religion and • Check if the employer qualifies as non-
the borrower submitted an older version of profit.
the ECF(DD/MM/YYYY) • If the employer qualifies as non-profit, leave
the hours per week field blank
• Send the "Denied EmQl □ y'ed by Religious
Org" manual denial letter.
The ECFis not completed and the employer Send the "Attached Certification-Action
attached the certification Reguired" manual denial letter.
The organization is still operational, and the Send the "lncomQlete or Missing Certification"
box on the form is checked indicating manual denial letter.
unable to obtain certification
The box is checked indicating the • See Section B2.3 ECFReguires Further
organization is closed or is refusing to Review for instruction
certify employment • On the old form with an expiration date of
11/30/2014, the box is located in Section 3.
• On the new form with an expiration date of
12/31/2017, the box is located in Section 2.
The borrower or employer requests FLSto • Deny the request through the system for
obtain employment certification from the reason that the certification sections
another source (such as a website) were not completed.
• Bypass the denial letter, and send the
"Unable to Obtain Certification-Action
Reguired" manual denial letter.
The ECFis certified with the entire public Send the "EmQloy'ment Certification Prior to
service employment period prior to the 10/01/2007" manual denial letter.
start of the PSLFProgram (10/1/2007)
The borrower is not employed (Example: Send the "Denied Not EmQIOy'edby<Public
indicates borrower is not a paid employee, Service Org" manual denial letter.
is a volunteer, a contractor, etc.)
d) Open the letter template needed for the borrower. Enter today's date at the top of the letter
i) The format must be MONTH DD, YYYY
ii) The month must be fully spelled out and in all capital letters.
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iii) The day must be two digits.

iv) The year must be four digits.
v) A comma must be between the day and the year.
e) Enter the borrower's name as it is displayed on~ If it is not a FLSborrower, use the name
displayed on~
i) The borrower's name must be in all capital letters.
ii) If a middle initial is listed, it must be used on the letter.
f) Enter the borrower's address as it is displayed on~ If it is not a FLSborrower, use the
name displayed o~(bJ(Bl I
i) The entire address must be capitalized.
ii) There must be no punctuation.
If Then
The suite number or apartment number Put the suite or apartment number AFTERthe
does fit on the same line as the delivery delivery address.
address
• Example:
JANE A DOE
2 MAIN ST APT 2
The suite or apartment number does not Put it on the line ABOVE the delivery address.
fit on the same line as the delivery address • Example:
JANE A DOE
APT 12
1234 MARTIN LUTHER KING JR
BLVDHARRISBURG PA 17106-9184
The full 9-digit zip code is listed • It must be used in the letter .
• You may place a hyphen in the zip code
3) Review the letter to ensure that no field within the body needs completed.
a) Some letters require additional information, such as an employer name or dates of
employment.
4) Once the letter is completed, save it in the 'PSLF LETTERQA' folder, stored in the Z drive.
a) (Location: fedloan_operations$ fbl(5l I
b) View the !Connect article onl(bl( l
5
Irassistance.
5) To save the letter:
a) Click File-> Save As
"°'(b~)(6ac)=~--------------------~
b) Select the
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c) (Z: drive users) Select the PSLF LETTERQA folder

d) Save the document as First Initial, Last Name, Date, SSN
6) A QA representative will review the letter and ensure that it meets all guidelines.
If Then
Errors are found • The QA representative will correct the

errors.
• Once the letter is correct, the QA rep will
image, print, and mail the letter to the
borrower.
• You will be alerted of the error via the QA
database.
No errors are found The QA will image, print and mail the letter to
the borrower.
B2.6 Process the RVECF ARC

1) The RVECF (PSLF REVIEW ECF)ARC is populated by processors or PSLFphone representatives
when an existing ECFentry or previously processed ECFneeds to be reviewed.
2) Review the request and make any necessary adjustments.
a) Review the indicated record along with ECFdocument and any additional information on file.
If Then
The request to update the record with missing Review to see if the ECFcan be processed.
information is received
All missing information is received Update the record with the information
We are still missing information that can be Call the employer to obtain the missing
obtained via phone call information
5
3) Comment the task onfbl( l rvith the adjustments that were made. See AES and FLS- Processing
Tasks Guide.
B2.7 Commenting on the PSLF Screen ( bl(6 1 )

(b)(6)
1) In COMPASS'M,press F4 from the~_~creen to comment.
a) An 'X' will automatically populate in the FORM field and the ECFsequence number will
automatically populate in the FORM SEQ field.
b) If you do not wish to comment under a specific form, you may select the option to comment
under General.
2) Press ENTER.
3) Press the Home key to place cursor to the top left of screen.
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4) Change the 'I' to a 'C' ~-

5) Press ENTER.
6) Reasons for commenting:
If Then Example
PH12345 01/01/2015- CALLED

Comment begins with your P EMPLOYER, LEFT MESSAGE
or PH# and date of comment. FOR AUTH OFFCL JANE DOE
Outbound calls All details of the call attempts DUE TO MISSING EIN. ADVSD
and/or conversations must be HRS OF OFFC & PHN # TO CLL
thoroughly documented. BCK.
Comment details as to what is PH12345 01/01/2015- EMPLYR

ECF is placed under Review
being reviewed. PLCD INTO DB FOR ADDTNL
status (Additional Review)
RVW.
Comment why the letter was PH12345 01/01/2015-SNT

Manual letter is sent sent. MNL LTTR TO BRWR ADVSNG
BOX 15 NOT CHCKD.
7) PSLFCall Comment Form f5R6'l7

a) Refer to the last row o~itional Letters/Forms table for a link to this form.
b) Complete this form if we do not have an SSNfor the borrower at the time of the call AND we
do not have a~ecord OR an account on COMPASS'M.
i) Complete the following fields of the PSCOM:
(1) Rep Name
(2)
PH#- If you do not have a PH# use your P#
(3)
Borrower Name
(4)
SSN (Use the one that was obtained)
(5)
Reason for Call
(a) Complete the Additional Comments Section
c) Once all needed fields have been completed, archive the image. See Section 82.8b PSCOM
Document.
B2.8 Archive Image
B2.Sa FileNet Imaging

1) When processing is completed, select Workflow Complete under Document Commands in FileNet
to archive the document. See the FileNet Imaging Procedures for more information.
B2.Sb PSCOM Document

1) To archive the PSCOM Document:
a) Double click Send to Imaging Icon on your desk.
i) If you do not have this application on your desktop
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(1) Open bJ(5l in My Computer

(2) Copy en o maging icon to the desktop.
b) Drag the PSCOM document you wish to archive to the "Drop File Here" icon.
c) Complete the attribute fields applicable.
i) SSN
ii) DOC ID
iii) ARC
d) Select OK to archive the document.
e) After the document is archived, delete the document from your desktop.
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Acronyms
ACP Automated Calling Process
CRM Customer Relationship Management
DCN Document Control Number
DLCO Direct Loan Consolidation Origination
DOD Department of Defense
DOE Department of Education
EIN Employer Identification Number
ED Exempt Organization
FEMA Federal Emergency Management Agency
FFELP Federal Family Education Loan Program
IBR Income-Based Repayment
ICR Income-Contingent Repayment
IDR Income-Driven Repayment
KC Knowledge Center
0MB Office of Management and Budget
NSLDS National Student Loan Data System
PAYE Pay As You Earn
PSECF Public Service Employment Certification Form
QA Quality Assurance
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SCRA Servicemembers Civil Relief Act
SSN Social Security Number
TLF Teacher Loan Forgiveness
Related Documents
Title
Location
AES and FLS- Electronic Signatures: How to Determine AcceQtable TyQes
Knowledge Base
AES and FLS- Processing Tasks Guide
Knowledge Base
COMPASS'M Navigation Training Guide
Content Connection
DemograQhics Index
Knowledge Center
Direct Loan Consolidation Organization
Knowledge Base
FileNet Imaging Procedures
Knowledge Base
FLS Income-Driven ReQayment Index
Knowledge Center
How to: Access the National Student Loan Data System (NSLDS)
Knowledge Center
How to MaQ the Z Drive
Knowledge Base
Knowledge Base
b)(6)
I- Re □avment Schedule Summarv Selection
NSLDS Training Overview

Knowledge Base
Phone Call Transfers and Holds Landing Page
Knowledge Center
Single Session HERA- New Shortcut
Knowledge Base
Su~er Screen User Guide
Knowledge Base
Time Zone Dialing
Knowledge Base
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Related Letters
FS06OPSLFA EmQl □ y'ment Certification Form (ECF)
FS06BECFAP ECFApproval Letter
FN06BECFAP ECFAQQroval Letter {Non-FLS borrower)
FS06BECFDN ECF Denial Letter
FN06BECFDN ECF Denial Letter {Non-FLS borrower}
Related Forms
Approval Letters
Name Location
(b)(6)
Loan Transfer Approved
Denial Letters
Name Location
I
Loan Transfer Denied - (b)(6)
Pending
Loan Transfer Denied - Paid
in Full
Loan Transfer Denied - High
Delinquency
Loan Transfer Denied -
Bankruptcy
Approved in Error- No
Eligible Loans
Approved in Error- Wrong

Employer
Approved in Error- Employer

for Profit, FLS Borrower
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(b)(6)
Approved in Error- Employer

for Profit, Non-FLS Borrower
Box 15 Not Checked
Invalid Employer
Identification Number (EIN)
EIN Missing
Cancellation Processed
Denial Correction
Not Employed by Public

Service Organization
Defaulted Loans
Loans Not Fully Disbursed
Employed by Religious
Organization
Employment Certification
Prior to 10.01.2007
Invalid ECF, Not 0MB

Approved
Action Required Letters
Name Location
I
b)(6)
Illegible Fax- ECR Received
Unable to Obtain Certification
- '
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(b)(6)
Request to Cancel - Loans

Already Transferred
Attached Certification
Denied Incomplete or Missing

Certification
Consolidated - New ECF

Required
Additional Letters/ Forms
Name Location
I
b)(6)
Welcome Letter
Consolidation/PSLF Welcome
Letter
Program Information for
Fedloan Borrowers
ECFCover Letter
Consolidated (Now Has

Eligible Loans)
DLCO- Interest in PSLF
DLCO- Qualifying Payments

PSLF
ECF Pending Review
Payment Tracking
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b)(6)
PSLFQualifying Payments
PSLFPotential Qualifying
Payments
Loan Summary Statement
PSLFCall Comment Form

(PSCOM)
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Screens
Se.oon System Mode Description

(b)(6)
COMPASS'" (b)(6) Automated Calling Process (ACP)
COMPASS'" Activity Records
COMPASS'" User Request
COMPASS'" Public Service Loan Forgiveness
COMPASS'" Billing History
COMPASS'" Borrower Detail
COMPASS'" Loan Detail
COMPASS'" Repayment Schedule Summary
COMPASS'" Borrower Demographics
Code Description
Name
b)(6)
N/A Plan Not Beneficial
N/A Plan Not Eligible
N/A Annual ECF Recertification
N/A Adjust School Enrollment Information
N/A Send Name Discrepancy Letter
N/A PSLFCallback Request
N/A Prevent Future PSLFCommunication
N/A PSLFCall Comment
Request a Special Letter to Provide Information

N/A Regarding the PSLFDenial
N/A ECFReview
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(b)(6)
N/A Manually Send the ECF
Date Approved is greater than one year from the date

N/A the new ECF is received.
N/A Comment the closed payment tracking task
Issues with repayment schedules require additional

N/A review
Triggered when an ECF is recertified to review

N/A payments prior to transfer not previously reviewed.
Trigger a review of history provided by the other

N/A servicer to verify/validate payments
N/A Review Error Made on the Account
Borrower or employer calls regarding employer

N/A eligibility or requests the ECFto be reviewed further.
N/A Payment Tracking Reviews/Expedited Requests
N/A Send the ECFvia Fax
Scripts
Administrator Description
Name
Used when leaving a message for a borrower regarding
Missing Demographics N/A missing demographics
Used when leaving a message for a borrower regarding

Missing ECF Information N/A missing information on the ECF
PageCenter Reports
Name Description
Pageset
b)(6)
PSECFReceived The Report tells us the current volume of the
(b)(6)
Remaining In Queue outs g ECFsreceived per day.
Report
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SAS Jobs- N/A

Other
Description
Name
The COMPASS'MServicing System is the system designed to service student loans.
The system organizes loan information so that staff can easily access detail to
COMPASS'" assist in servicing. In addition, the system's capabilities are limitless, as it can be
modified by programmers to meet the needs of our clients and customers
An internal business product that stores system procedures; accessible via

Content Connection Pathways,rl( 5l
I
A web-based imaging system that stores all incoming correspondence; accessible
File Net
vial(bJ(6J I
The server to which users connect to access the (COM PASS'M/OneLINK/FAST)
HERA system on the mainframe. The server is accessed using an IBM software called
"Reflection," but commonly referred to as HERA.
A web-based intra net product that serves as a one-stop location for procedures,
IConnect/ Knowledge phone scripts, e-mail canned responses, industry definitions, and other resources;
Base accessible vi~(bJ(Bl I
A CRM (Customer Relationship Management) Knowledge Management tool
Knowledge Center
The Department of Education's database for student aid, with information from
The National Student school, guarantors, etc. Accessible via
Loan Database System htt~s:LLwww.nsldsfa~.ed.gov Lnsld s FAPLdefa u It. js~
PageCenter is an intranet-based tool for requesting reports, payment histories,
PageCenter error lists, sent letters, etc. Accessible via

b)(6)
I
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Appendix A - Loan Abbreviations
A.1 FFELP and Direct Loan Abbreviations Chart
Loan Types FFELP Direct

Subsidized Stafford STFFRD DLSTFD
Unsubsidized Stafford UNSTFD DLUNST
SDCL - Subsidized Stafford N/A DLSCST
SDCL- Unsubsidized Stafford NA DLSCUN
TEACH- Unsubsidized N/A TEACH
Consolidation CNSLDN DLCNSL

Subsidized Consolidation SUBCNS DLSCNS
Unsubsidized Consolidation UNCNS DLUCNS
SDCL- Consolidation N/A DLSCCN
SDCL - Subsidized Consolidation N/A DLSCSC
SDCL - Unsubsidized Consolidation N/A DLSCUC
Parent PLUS PLUS DLPLUS

Graduate/ Student PLUS PLUSGB DLPLGB
SDCL- Parent PLUS N/A DLPCNS
SDCL - Graduate/ Student PLUS N/A DLSCPG
Federal Insured Student Loan FISL N/A

SDCL - Federal Insured Student Loan N/A DLSCST
Supplemental Loan for Students SLS N/A
SDCL - Federal Supplemental Loan for
N/A DLSCST
Students
Guaranteed Student Loans GSL N/A
SDCL - Guaranteed Student Loans N/A DLSCST
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Resources/Authority
34 CFR 685.219
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SOLICITATION/CONTRACT/ORDER FOR C01v1MERCIAL ITEMS 1 REQUISITION NUMBER PAGE 1 OF 72

OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30 EDOFSA-09-000621
2. CONTRACT NO. J. AWARD/ffFECTIVE 4, ORDER NUMBER 5. SDL:CITATlmJ NUM!l[ll 6. SOLICITATION ISSUE
llATE DATE
ED-FSA-09-D-0014
JUN 17, 2009
a NAME o. TCL[PltoNE NUMBER /No ,ctlect OFFERDUE DATE/
7. FOR SOLICITATION
INFORMATION CALL:
• Nicholas Chung calls} 202-377-3635 ' LOCAL TIME
nrcholas.chung@ed gov
9, ISSUED BY
IFSA-FS2 THIS ACOUISITON IS

CODE
" OuNR~srn1crrn OR OsET
AsI0E,. % FOR:
Federal Student Aid/Mission Support Group D SMALL BUSINESS □ EMERGING SMALL
BUSINESS
830 First SI NE - Suite 91 F3 □ HUBZONE SMALL
Washington DC 20202 NAICS: BUSINESS
SIZE STANDARD: Osrnv1ce.01sABLED VETERAN- O BIAI
OWNED SMALL BUSINESS
DELIVERY FOR FOB DESTINA·
" TION UNLESS BLOCK IS
MARKED
12. DISCOUNT TEllMS
0 Days tJ 13a. THIS CONTRACT IS A
!Jb. RATING
AA TED OAOER UNDER

0% 14. METHOD OF SOLICITATION
DPAS (\5 CFR 7001
_[l SEE SCf.<fDUL[ Net 30
□ Rm 01FB □ RFP
16. DELIVER TO CODE I 16. AOMIN!STERED BY
CODE IFSA-FS2
Federal Studenl Aid/Mission Support Group
830 First St NE - Suite 91 F3
17a.
OFFEROR co0Elooo30774 1 FAC!UTY 188. PAYMENT W!LL BE MADE BY
CODE I
CODE
HIGHER EDUCATION ASSISTANCE AGE!'ffi; ~1693362
1200 NORTH 7TH STREET CAGE: 41UK7
FINANCIAL MANAGEMENT 5TH FLOOBUNS:007368103
HARRISBURG PA 171021444
TELEPHONE NO.
18b, SlJ8MIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK
□ nb. CHFC:KIF REMITTANCE IS DIFFERENTAND PUT SUCH AODRESS IN
BELOW IS CHECKED
OFFER
[I Sff AOOFNl"JUM
"· ,0 n n
lTrMNO, SCHEDULE OF SUPPLICS/SERVICES "
OUA,',,ITITY U,',,IIT UNIT PRICE "
AMOUNT
Please see continuation page for line item details.
!Use Reveroa ~nd/or Anach Ad<li/lQ1>AIShee/$ dS Necusorv/

2f>, ACCOUNTINU .AND APPROPRIATION DATA 26. TOT AL AWARD AMOUNT /Fot Gavr. Use Only}
i
See Schedule $5,000,000.00
b-1270. SOUClTATIONINCORPORATES
BY REFERENCE
FAR!i2 212·!. 51,212•4, FAA52.2124 Al-0 52.212·5 AR£ ATTACHEO.AOOENOA /71ARE HARE NOTATTACKEO
27b. CONTF!ACT1f>\.Jf1CHASE
0A0Ffl INCORPOF!ATES
IIY f\H£11ENCE
FAR52.212-4. FAR 52.212•5 IS ATTACHED.ADDENDA / AME Aft£ NOT ATTACHED
-·- ---
~ 28. CONTRACTOR IS RECUIRfD TO SIGN THIS DOCUMENT ANO RHURN 1 29. AWARD OF CONTRACT, REF.
COPIES TO ISSUING OFFICE. CONTRACTOR AGREES TO FURNISH AND ---
DATED------ . YOUAO(FER ON SOLICITATION
DELIVER ALL ITEMS SET FORTH OR OTHERWISE IOENT!FtEOABOVE ANO ON ANY IBLOC~ 5), INCLUDING ANY AOOITION!l OR CHANGES WHICH ARE
ADDITIONAL SHEETS SUBJECT TO THE HAMS AND CONDITIONS SPECIFlfD SET FORTH HEREIN, IS ACCEPTED AST ITEMS:
3Da. s (b)(B) G OFFICER}

b)(6)
30b. N c. DATE SIGNH) Jib. NAME OF ONTAACTING OFFICER/Type or p:mr/ 31c. DATE SIGNED°
Mike Wnisler
President & CEO 06.-17.'09
1.,,/,-1·~
AUTHORIZED FOR LOCAL REPRODUCTION STANDARD FORM 1449 (REV. 3120051
PREVIOUS EDITION IS NOT USABLE P,ncribod by GSA• FAR (46 CFR) 63.212
rn. ,c n n n.
ITEM NO. SCHEDULE OF SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE "
AMOUNT
32a. QUANTITY IN COLUMN 21 HAS BEEN
□ RECEIVED □ INSPECTED □ ACCEPTED, AND CONFORMS TO THE CONTRACT, EXCEPT AS NOTED:
32b. SIGNATURE OF AUTHORIZED GOVERNMENT 32c. DATE 32d. PRINTED NAME AND TITLE OF AUTHORIZED GOVERNMENT
REPRESENTATIVE REPRESENTATIVE
32e. MAILING ADDRESS OF AUTHORIZED GOVERNMENT REPRESENTATIVE 321. TELPHONE NUMBER OF AUTHORZED GOVERNMENT REPRESENTATIVE
32g. E-MAIL OF AUTHORIZED GOVERNMENT REPRESENTATIVE
33. SHIP NUMBER 34. VOUCHER NUMBER 35. AMOUNT VERIFIED 36. PAYMENT 37. CHECK NUMBER
CORRECT FOR
□ COMPLETE □ PARTIAL □ FINAL
!PARTIAL I IFINAL
38. S.'R ACCOUNT NO. 39. S.'R VOUCHER NUMBER 40. PAID BY
41a. I CERTIFY THIS ACCOUNT IS CORRECT AND PROPER FOR PAYMENT 42a. RECEIVED BY (Prinl!
41b. SIGNATURE AND TITLE OF CERTIFYING OFFICER 41c. DATE
42b. RECEIVED AT !Locarion)
42c. DATE REC'D (YYIMMIDD! 142d. TOTAL CONTAINERS
STANDARD FORM 1449 IREV. 3/2005) BACK
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN Continued
SCHEDULE FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
ITEM NO. SUPPLIES.'SERVICES QUANTITY UNIT UNIT PRICE S AMOUNT $
Accounting and Appropriation Data:

O198M2009 .A.2009. EN 800000. 6P2. 25 72A. C26. 000. 0000 000000
Cost Applied: $5.000,000.00
0001 IDIQ Base Ordering Period Award Minimum Guarantee 1.00 SE 5,000,000.00 5,000,000.00
Period of Performance: 06/17/2009 - 06/16/2014
0002 OPTION - Optional Ordering Period 1.00 EA 0.00 0.00
Optional Period of Performance: 06/17/2014 -

06/16/2019
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN

PAGE 2FEDERATION
OF OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
A. ADDENDUM 1-SF 1449 CONTINUATION PAGE
(This page left blank intentionally.)
Solicitation Number: PSA-TitlclV-09 Page I of 20
B. ADDENDUM 2 - 52.212-4, CONTRACT TERMS AND CONDITIONS-

COMMERCIAL ITEMS (MAR 2009)
B.l 52.212-4 Contract Terms And Conditions-Commercial Items (Mar 2009)-

TAILORED
(c)(l) Changes. The Contracting Officer may at any time, by written order. and without notice
to the sureties, if any, make changes within the general scope of this contract in any one
or more of the following:
(i) Description of services to be performed.
(ii) Time of performance (i.e .. hours of the day, days of the week, etc.).
(iii) Place of performance of the services.
(2) If any such change causes an increase or decrease in the cost of, or the time
required for, performance of any part of the work under this contract, whether or
not changed by the order. the Contracting Officer shall make an equitable
adjustment in the contract price. the delivery schedule, or both, and shall modify
the contract.
(3) The Contractor must assert its right to an adjustment under this clause within 30
days from the date of receipt of the written order. However, if the Contracting
Officer decides that the facts justify it, the Contracting Officer may receive and
act upon a proposal submitted before final payment of the contract.
(4) If the Contractor's proposal includes the cost of prope11y made obsolete or excess
by the change, the Contracting Officer shall have the right to prescribe the manner
of the disposition of the property.
(5) Failure to agree to any adjustment shall be a dispute under the Disputes clause.
However, nothing in this clause shall excuse the Contractor from proceeding with
the contract as changed.
B.2 52.252-2 Clauses Incorporated By Reference (Feb 1998)

This contract incorporates one or more clauses by reference, with the same force and effect as if
they were given in full text. Upon request. the Contracting Officer will make their full text
available. The full text of a clause may also be accessed electronically at:
http://www.amet.gov/far/
• 52.203-13 Contractor Code of Business Ethics and Conduct (Dec 2008)
• 52.203-14 Display of Hotline Poster(s) (Dec 2007)
• 52.209-6 Protecting the Government's Interest when Subcontracting with
Contractors Debarred. Suspended, or Proposed for Debarment (SEP 2006)
• 52.216-18 Ordering (OCT 1995)
(a) the effective date of awanl, the end of the current period of
performance
• 52.216-19 Ordering Limitations (OCT 1995)
(a) One Borrower
(b)(l) Five Million Borrowers
(b)(2) Five Million Borrowers
(b)(3) Two Days
(d) One Day
• 52.216-22 Indefinite Quantity (OCT 1995)
Solicitation Number: PSA-TitlclV-09 Page 2 of 20
(d) the end of the current period of performance

• 52.216-27 Single Or Multiple Awards (OCT 1995)
• 52.217-8 Option To Extend Services (NOV 1999)
• 52.217-9 Option to Extend the Term of the Contract (MAR 2000)
• 52.224-l Privacy Act Notification (APR 1984)
• 52.224-2 Privacy Act (APR 1984)
B.3 EDAR 3452.202-1 Definitions (Aug 1987) -TAILORED

(a) The term "Secretary" or "Head of the Agency" (also called "Agency Head") means the
Secretary of the Department of Education; and the tenn "his/her duly authorized
representative" means any person, persons, or board authorized to act for these officials.
(b) "Chief Acquisition Officer" or ''CAO" means the official responsible for monitoring the
agency's acquisition activities, evaluating them based on applicable performance
measurements, increasing the use of full and open competition in agency acquisitions,
making acquisition decisions consistent with applicable laws, and establishing clear lines of
authority, accountability, and responsibility for acquisition decision-making and developing
and maintaining a acquisition career management program.
(c) "Chief of the Contracting Office" means an official serving in the contracting activity (CAM
or FSA Acquisitions) as the manager of a group that awards and administers contracts for a
principal office of the Department. See also definition of ''Head of Contracting Activity"
below.
(d) "Contracting Officer's Representative" or "COR" means a government employee appointed
in writing ONLY by a contracting officer and delegated limited responsibilities to perform
specified contract management duties related to technical oversight and administration of a
specific contract. CO Rs may serve in a full-time or part-time capacity. The COR performs
the contract management duties assigned by the CO in a written "Contracting Officer's
Representative Designation Memorandum" for each particular contract. Multiple CORs may
be appointed for a single contract when the area of expertise necessary requires such
appointments. The CO may appoint alternate or assistant CORs to serve in the COR's
absence. For the purpose of this program, the term Contracting Officer's Technical
Representative (COTR) will be used for assistant CORs.
(e) "Head of the Contracting Activity'' or "HCA" means those officials within the Department of
Education who have responsibility for and manage an acquisition organization and usually
hold unlimited procurement authority. The Director, Federal Student Aid Acquisitions, is the
HCA for FSA. The Director, Contracts and Acquisitions Management (CAM) is the HCA for
all other Depa1tmental program offices and all boards, commissions, and councils under the
management control of the Depa1tment.
(t) ''Performance-Based Organization" or "PBO" is the office within the Department that is
mandated by Public Law 105-244 to carry out Federal student assistance or aid programs and
report to Congress on an annual basis. It may also be referred to as "Federal Student Aid.''
(g) "Senior Procurement Executive'' or "SPE" means the single agency official appointed as such
by the head of the agency and delegated broad responsibility for acquisition functions,
including issuing agency acquisition policy and reporting on acquisitions agency-wide. The
SPE also acts as the official one level above the contracting officer when the HCA is acting
as a contracting officer.
(h) "Department" or "ED" means the United States Department of Education.
Solicitation Number: PSA-TitlclV-09 Page] of 20
B.4 ED 307-17 Conflicts Of Interest (Aug 2007)

(a) The contractor, subcontractor. employee or consultant. has certified that. to the best of their
knowledge and belief, there are no relevant facts or circumstances which could give rise to an
organizational or personal conflict of interest, (see FAR Subpatt 9.5 for organizational
conflicts of interest), (or apparent conflict of interest) for the organization or any of its staff,
and that the contractor. subcontractor. employee or consultant has disclosed all such relevant
information if such a conflict of interest appears to exist to a reasonable person with
knowledge of the relevant facts (or if such a person would question the impa11iality of the
contractor, subcontractor. employee or consultant). Conflicts may arise in the following
situations:
(1) Unequal access to information- a potential contractor, subcontractor, employee or
consultant has access to non-public information through its performance on a government
contract.
(2) Biased ground rules - a potential contractor. subcontractor, employee or consultant has
worked, in one government contract, or program, on the basic structure or ground rules of
another government contract,
(3) Impaired objectivity - a potential contractor, subcontractor. employee or consultant, or
member of their immediate family (spouse, parent or child) has financial or other
interests that would impair, or give the appearance of impairing, impaitialjudgment in
the evaluation of government programs, in offering advice or recommendations to the
government. or in providing technical assistance or other services to recipients of Federal
funds as part of its contractual responsibility.
"Impaired objectivity" includes but is not limited to the following situations that would
cause a reasonable person with knowledge of the relevant facts to question a person's
objectivity:
(i) financial interests or reasonably foreseeable financial interests in or in connection
with products. property. or services that may be purchased by an educational agency.
a person, organization, or institution in the course of implementing any program
administered by the Department;
(ii) significant connections to teaching methodologies that might require or encourage the
use of specific products. property or services; or
(iii)significant identification with pedagogical or philosophical viewpoints that might
require or encourage the use of a specific curriculum, specific products, prope11y or
services,
Offerors must provide the disclosure described above on any actual or potential conflict
(or apparent conflict of interest) of interest regardless of their opinion that such a conflict
or potential conflict (or apparent conflict of interest) would not impair their objectivity.
In a case in which an actual or potential conflict (or apparent conflict of interest) is
disclosed, the Department will take appropriate actions to eliminate or address the actual
or potential conflict (or apparent conflict of interest), including but not limited to
mitigating or neutralizing the conflict, when appropriate, through such means as ensuring
a balance of views. disclosure with the appropriate disclaimers, or by restricting or
modifying the work to be perfonned to avoid or reduce the conflict. In this clause, the
term "potential conflict" means reasonably foreseeable conflict of interest.
(b )The contractor, subcontractor, employee or consultant agrees that if ''impaired objectivity, or

an actual or potential conflict of interest (or apparent conflict of interest) is discovered after
the award is made, it will make a full disclosure in writing to the Contracting Officer. This
disclosure shall include a description of actions that the Contractor has taken or proposes to
take, after consultation with the Contracting Officer, to avoid. mitigate, or neutralize the
actual or potential conflict (or apparent conflict of interest).
(c) Remedies - The Government may terminate this contract for convenience, in whole or in
part. if it deems such termination necessary to avoid the appearance of a conflict of interest.
If the Contractor was aware of a potential conflict of interest prior to award or discovered an
actual or potential conflict (or apparent conflict of interest) after award and did not disclose
or misrepresented relevant infonnation to the Contracting Officer, the Government may
terminate the contract for default. or pursue such other remedies as may be permitted by law
or this contract. These remedies include imprisonment for up to five years for violation of
Title 18, U.S. Code, § I 001 and fines of up to $5000 for violation of Title 31, U.S. Code, §
3802. Further remedies include suspension or debarment from contracting with the federal
government. The Contractor may also be required to reimburse the Department for costs the
Department incurs arising from activities related to conflicts of interest. An example of such
costs would be those incurred in processing Freedom of Information Act requests related to a
conflict of interest.
(d) In cases where remedies short of termination have been applied, the contractor.
subcontractor. employee or consultant agrees to eliminate the organizational conflict of
interest, or mitigate it to the satisfaction of the Contracting Officer.
(e) The Contractor further agrees to insert in any subcontract or consultant agreement hereunder,
provisions which shall conform substantially to the language of this clause, including specific
mention of potential remedies and this paragraph (e).
B.5 EDAR 3452.208-70 Printing (Aug 1987)

Unless otherwise specified in this contract, the contractor shall not engage in, nor subcontract
for, and printing (as that term is defined in Title I of the Government Printing and Binding
Regulations in effect on the effective date of this contract) in connection with the performance of
work under this contract; except that performance involving the reproduction of less than 5,000
production units of any one page. or less than 25,000 production units in the aggregate of
multiple pages, shall not be deemed to be printing. A production unit is defined as one sheet, size
8 1/2 by 11 inches, and one side and color only.
B.6 FSA 24-1 Release Of Information Under The Freedom Of Information Act (Jan
2008)-TAILORED
By entering into a contract with the Department of Education and as pennitted/authorized by
existing statutes and applicable case law. without regard to proprietary markings. the contractor
approves the release of the entire contract and all related modifications and task orders.
including, but not limited to:
(1) Unit prices, including labor rates,
(2) Statements of Work/Performance Work Statement generated by the contractor,
(3) Performance requirements. including incentives, performance standards. quality levels
and service level agreements,
(4) Reports, deliverables and work products delivered in performance of the contract
(including quality of service, performance against requirements/standards/service level
agreements),
(5) Any and all information, data, software and related documentation first provided under
the contract,
(6) Proposals or portions of proposals incorporated by reference, and
(7) Other terms and conditions.
B.7 FSA 27-1 Labeling Of Documents (.June 2007)-TAILORED

The Contractor shall not label any data, as defined in the clause at 52.227-14, produced in
performance of this contract in a way that would restrict the Government's right to use or release
the information. If applicable, the Contractor shall include a legend that identifies sensitive data
that should not be released for security reasons. Under FAR 52.227-14, Rights in Data-General
(or 52.227-15, -16, -17) clause, this data may be used for any public purpose. Deliverables shall
not contain vendor-specific logos, mottos, watermarks, or holograms.
The Contractor shall not use, particularly for proposals, U.S. Government logos, such as the U.S.
Department of Education or Federal Student Aid.
B.8 FSA 27-2 Limitations On The Use Or Disclosure Of Government-Furnished

Information Marked With Restrictive Legends (Dec 2006)
(a) For contracts under which data are to be produced, furnished, or acquired, the terms "limited
rights" and ''restricted rights" are defined in the Rights in Data - General clause of this
contract.
(b) Proprietary data, technical data or computer software provided to the Contractor as
Government furnished information (GFI) under this contract may be subject to restrictions on
use, modification, reproduction, release, performance, display, or further disclosure.
(I) Proprietary data with legends that sen,e to restrict disclosure or use of data. The
Contractor shall use, modify, reproduce, perform, or display proprietary data received
from the Government with proprietary or restrictive legends only in the performance of
this contract. The Contractor shall not, without the express written permission of the
party who owns the data, release or disclose such data or software to any person.
(2) GFI marked with limited or restricted rights legends. The Contractor shall use, modify,
reproduce, perform, or display technical data received from the Government with limited
rights legends or computer software received with restricted rights legends only in the
performance of this contract. The Contractor shall not, without the express written
permission of the party whose name appears in the legend, release or disclose such data
or software to any person.
(3) GFI marked •,vithspecially negotiated license rights legends. The Contractor shall use,
modify, reproduce, release, perform, or display proprietary data, technical data or
computer software received from the Government with specially negotiated license
legends only as permitted in the license. Such data or software may not be released or
disclosed to other persons unless permitted by the license and, prior to release or
disclosure, the intended recipient has completed the use and non-disclosure agreement.
The Contractor shall modify paragraph (l)(c) of the use and non-disclosure agreement to
reflect the recipient's obligations regarding use, modification, reproduction, release,
performance, display, and disclosure of the data or software.

(c) Indemnification and creation of third party beneficiary rights.
( 1) The Contractor agrees to indemnify and hold harmless the Government, its agents, and
employees from every claim or liability, including attorneys fees, court costs, and
expenses, arising out of, or in any way related to, the misuse or unauthorized
modification, reproduction, release, perfonnance, display, or disclosure of proprietary
data, technical data or computer software received from the Government with restrictive
legends by the Contractor or any person to whom the Contractor has released or disclosed
such data or software.
(2) The Contractor agrees that the patty whose name appears on the restrictive legend, in
addition to any other rights it may have, is a third party beneficiary who has the right of
direct action against the Contractor, or any person to whom the Contractor has released or
disclosed such data or software, for the unauthorized duplication, release, or disclosure of
proprietary data, technical data or computer software subject to restrictive legends.
B.9 FSA 27-3 Use And Non-Disclosure Agreement

(a) Except as provided in paragraph (b) of this clause, proprietary data, technical data or
computer software delivered to the Government with restrictions on use, modification,
reproduction, release, performance, display, or disclosure may not be provided to third
parties unless the intended recipient completes and signs the use and non-disclosure
agreement at paragraph (c) of this clause prior to release or disclosure of the data.
( 1) The specific conditions under which an intended recipient will be authorized to use,
modify, reproduce, release, perform, display, or disclose proprietary data or technical
data subject to limited rights, or computer software subject to restricted rights must be
stipulated in an attachment to the use and non-disclosure agreement.
(2) For an intended release, disclosure, or authorized use of proprietary data, technical data
or computer software subject to special license rights, modify paragraph ( 1)(d) of the use
and non-disclosure agreement to enter the conditions, consistent with the license
requirements, governing the recipient's obligations regarding use, modification,
reproduction, release, performance, display or disclosure of the data or software.
(b) The requirement for use and non-disclosure agreements does not apply to Government
contractors which require access to a third party's data or software for the performance of a
Government contract that contains the clause, Limitations on the Use or Disclosure of
Government Furnished Information Marked with Restrictive Legends.
(c) The prescribed use and non-disclosure agreement is:
USE AND NON-DISCLOSURE AGREEMENT

The undersigned, _(Insert Name)_, an authorized representative of the _(Insert
Company Name) __ , (which is hereinafter referred to as the "Recipient") requests the
Government to provide the Recipient with proprietary data, technical data or computer
software (hereinafter referred to as ''Data") in which the Government's use, modification,
reproduction, release, performance, display or disclosure rights are restricted. Those Data are
identified in an attachment to this Agreement. In consideration for receiving such Data, the
Recipient agrees to use the Data strictly in accordance with this Agreement:
(!)The Recipient shall -
(a) Use, modify, reproduce, release, perform, display, or disclose Data marked with
SBIR data rights legends only for government purposes and shall not do so for any
commercial purpose. The Recipient shall not release, perform, display, or disclose
these Data, without the express written permission of the contractor whose name
appears in the restrictive legend (the "Contractor''), to any person other than its
subcontractors or suppliers, or prospective subcontractors or suppliers, who require
these Data to submit offers for, or perform, contracts with the Recipient. The
Recipient shall require its subcontractors or suppliers, or prospective subcontractors
or suppliers, to sign a use and non-disclosure agreement prior to disclosing or
releasing these Data to such persons. Such agreement must be consistent with the
terms of this agreement.
(b) Use, modify, reproduce, release, perform, display, or disclose proprietary data or
technical data marked with limited rights legends only as specified in the attachment
to this Agreement. Release, performance, display, or disclosure to other persons is not
authorized unless specified in the attachment to this Agreement or expressly
permitted in writing by the Contractor.
(c) Use computer software marked with restricted rights legends only in performance of
Contract Number _(insert contract number(s)) _. The Recipient shall not, for
example, enhance, decompile, disassemble, or reverse engineer the software; time
share, or use a computer program with more than one computer at a time. The
recipient may not release, perform, display, or disclose such software to others unless
expressly permitted in writing by the licensor whose name appears in the restrictive
legend.
(d) Use, modify, reproduce, release, perform, display, or disclose Data marked with
special license rights legends (To be completed by the contracting officer. See (a)(2)
of the Use and Non-Disclosure Agreement clause. Omit if none of the Data requested
is marked with special license rights legends).
(2) The Recipient agrees to adopt or establish operating procedures and physical security
measures designed to protect these Data from inadvertent release or disclosure to
unauthorized third parties.
(3) The Recipient agrees to accept these Data ''as is" without any Government representation
as to suitability for intended use or warranty whatsoever. This disclaimer does not affect
any obligation the Government may have regarding Data specified in a contract for the
performance of that contract.
(4) The Recipient may enter into any agreement directly with the Contractor with respect to
the use, modification, reproduction, release, performance, display, or disclosure of these
Data.
(5) The Recipient agrees to indemnify and hold harmless the Government, its agents, and
expenses arising out of, or in any way related to, the misuse or unauthorized
modification, reproduction, release, perfonnance, display, or disclosure of Data received
from the Government with restrictive legends by the Recipient or any person to whom the
Recipient has released or disclosed the Data.
(6) The Recipient is executing this Agreement for the benefit of the Contractor. The
Contractor is a third party beneficiary of this Agreement who, in addition to any other
rights it may have, is intended to have the rights of direct action against the Recipient or
any other person to whom the Recipient has released or disclosed the Data, to seek
damages from any breach of this Agreement or to otherwise enforce this Agreement.
(7) The Recipient agrees to destroy these Data, and all copies of the Data in its possession.
no later than 30 days after the date shown in paragraph (8) of this Agreement, to have all
persons to whom it released the Data do so by that date, and to notify the Contractor that
the Data have been destroyed.
(8) This Agreement shall be effective for the period commencing with the Recipient's
execution of this Agreement and ending upon _(Insert Date)_. The obligations
imposed by this Agreement shall survive the expiration or termination of the Agreement.
Recipient's Business Name
Authorized Representative Date
Representative's Typed Name and Title
B.10 FSA 31-1 Proposal Cost And/Or Pricing Data (August 2008)
Federal Student Aid intends to collect cost, pricing and technical information submitted in
response to proposals. Information will be evaluated and stored in Federal Student A id's Cost
Library in order to expand the organizations historical pricing data and cost estimating
capabilities.
B.11 FSA 32-1 Invoice Procedures (August 2007)

The Contractor must submit a physical invoice via either mail. fax or e-mail for this contract in
order to be paid for products and/or services rendered.
Federal Student Aid's "designated billing office" is:
US Department of Education
Union Center Plaza
Federal Student Aid Administration
830 First Street, NE, Suite 54B 1
Washington, D.C. 20202-0001
E-mail: InvoiceAdmin@ed.gov
Fax: 202-275-3477
The Contractor shall also simultaneously submit copies of the invoice to the Contracting Officer
and one to the Contracting Officer's Representative (COR). The CO and COR should receive
copies via the same means as the invoice sent to the Budget Group.
When submitting an invoice via mail, the Contractor shall submit the original invoice AND two
copies of the invoice.
At a minimum the following items must be addressed in order for the invoice to be considered
"proper" for payment:
(1) Name and Address of the Contractor.

(2) Invoice Number and Invoice Date (Date invoices as close as possible to the date of
mailing or transmission. The date and actual submission must occur after receipt.
inspection and acceptance of the supplies or services.)
(3) The Contract number, contract line item, and if applicable, the order number must be
included on the invoice and be correct.
(4) Description, quantity, unit of measure, unit price, and extended price of the item
delivered must agree with the contract or order.
(5) Terms of any prompt payment discount offered.
(6) Name, title, and phone number of persons to be notified in event of defective invoice.
(7) The period of time covered by the invoice must include the first and last day of the
period.
(8) Totals must be supported by subtotals and subtotals should be supported by detail, (i.e.
documentation for categories of labor, hours performed, unit prices) and deliverables
provided.
(9) If required by this contract or order, receipts must be provided to support documentation
of "other direct costs" (ODCs) or materials.
B.12 AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009 (Pub.L. 111-5)

In the event funds are utilized on this contract originating from the American Recovery and
Reinvestment Act of 2009, or other discrete legislation, the following clauses, or similar clauses,
shall apply:
• 52.203-15 Whistleblower Protections Under The American Recovery And
Reinvestment Act Of2009 (Mar 2009)
• 52.204-11 American Recovery And Reinvestment Act-Reporting Requirements
(Mar 2009)
• 52.212-5 Contract Terms and Conditions Required to Implement Statutes or
Executive Orders-Commercial Items (Mar 2009)-Alternate II (Mar 2009)
• 52.215-2 Audit And Records-Negotiation-Alternate I (Mar 2009)
• EDAR 3403-1 Self Reporting Of Violations - Recovery Act (Feb 2009)
The contractor and subcontractor shall promptly refer to an appropriate inspector general
any credible evidence that a principal, employee, agent, contractor, sub-grantee or
subcontractor has committed a violation of Federal criminal law involving fraud, conflict
of interest. bribery, or gratuity violations found in Title 18 U.S.C. or a violation of the
civil False Claims Act (31 U.S.C. 3729-3733).
B.13 ADDITIONAL TERMS AND CONDITIONS

A. Contract Type-Indefinite Delivery/Indefinite Quantity (IDIQ). During the course of the
basic ordering period, the Government will provide a minimum of $5,000,000.00 in revenue,
provided that the contractor is in compliance with the requirements for servicing federally
held debt, and the maximum volume for the basic ordering period agreement will be 50
million boJTowers. The Optional Ordering Period will have a minimum of $0 and a
maximum of an additional 50 million borrowers
B. Ordering Period-The ordering period for this contract will be one (1), five (5) year Base
Ordering Period, with one (I) additional five (5) year Optional Ordering Period.
Solicitation \lumber: PSA-TitlclV-09 Page 10 of 20
C. Requirements Deadlines-The contractor shall comply with the following compliance

requirements deadlines:
(I) The contractor shall meet the Initial Requirements by August 31. 2009 for servicing
federally held debt. If these are met, FFEL servicing may begin.
(2) The contractor shall meet the Intermediate Requirements by March 31, 2010 (unless
otherwise noted within the Intermediate Requirements document). for servicing federally
held debt. If all requirements are not met. the Government may elect to not assign further
volume to the contractor. Furthermore, the Government may transfer currently held
accounts to another servicer. The contractor losing the accounts shall bear the costs of
any such transfer.
(3) The contractor shall meet the Full Requirements by August 31. 2010 for Direct Loan
servicing. If the Government determines the requirements are not met, the Government
may elect to not assign further volume to the contractor. Furthermore, the Government
may transfer currently held accounts to another servicer. The contractor losing the
accounts shall bear the costs for any such transfer.
D. Quarterly Compliance Monitoring-[Reserved]
E. Annual Compliance Audit-[Reserved]
F. Allocation Methodology-See Attachments A-4 and A-5.
G. Allocation Metrics- See Attachments A-4 and A-5.
H. Performance Incentives/Metrics-[Reserved]
I. Price Definitions-See Attachment A-6.
J. Work Performed Outside the Continental United States-The Contractor has represented
to the Department that it will perform all work required under this Contract within the United
States. If, at any time, the Contractor wishes to perfonn any Contract work outside the United
States, the Contractor shall infonn the Contracting Officer, in advance and in writing, of its
intention and request the Department's approval. The Contractor shall not perform any
Contract work outside the United States unless and until it has received the Contracting
Officer's explicit, written approval to perform such work. In order to give proper
consideration to the Contractor's request, the Department may ask for, and the Contractor
shall provide. information relevant to the proposed performance outside the United States.
including but not limited to a detailed description of the physical, personnel and management
resources to be used and any potential difficulties or constraints in performing in the foreign
jurisdiction. The Department may refuse to approve Contract performance outside the United
States to the extent that. solely in the Department's judgment. the Contractor has not shown
that performance outside the United States would satisfy the Contract requirements and
would not impair or degrade perfonnance. Further, the Department may refuse to approve
any performance outside the United States for any other reason, or for no reason, except as
otherwise required by the laws and treaties of the United States. The Department also may
approve performance outside the United States subject to certain conditions. to which
conditions the Contractor shall strictly adhere. Neither perfonnance within the United States,
nor the Department's refusal to allow performance outside the United States shall ever
constitute a change to this Contract or give rise to any entitlement to additional compensation
or excuse any failure of performance by the Contractor. Nothing in this clause shall be
interpreted to impose any obligation on the Department to allow or to refuse a request for
perfonnance of this Contract outside the United States.
Solicitation \lumber: PSA-TitlclV-09 Page 11 of20
K. Branding/Marketing Material-Contractors may not solicit or promote other

services/products they, or their affiliates, offer while servicing Depa1tment of Education
borrowers, or Federally held debt. This includes all communication channels and touch
points, such as but not limited to: inbound and outbound calls/email, web pages, any mailings
specific to the status of their account, direct personal and automated interaction, etc.
Scenarios: ( 1) if the servicer services Federally and non-Federally held debt and offers
combined billing, no marketing envelopes or inserts for other services/products may be
issued; (2) if the servicer services Federally and non-Federally held debt and does NOT use
combined billing, normal marketing may be provided for non- Federally held debt for other
services/products; and (3) if the servicer services Federally and non-Federally held debt and
is in personal contact, no marketing for other services/products may be discussed. If a
borrower with in-school status seeks information regarding other products or services from
the servicer, the borrower shall be directed to their schoor s Student Financial Assistance
Office.
Any exception or ambiguity regarding the above shall be reviewed and approved by the
Contracting Officer in advance.
L. Invoicing and Non-Compliance - Borrowers whose loans are not being serviced in
compliance with the Requirements, Policy and Procedures for servicing federally held debt
due to the fault of the servicer (i.e. correct interest calculations, correct balances, interest
determination and calculations, notices sent properly, proper due diligence, etc.), will not be
billable to the Government from the initial point of non-compliance. Any funds that have
been invoiced for these borrowers and paid shall be returned to the Government via a credit
on the next invoice.
M. Contracting Otlicer's Representative -The following individual is designated as
Contracting Officer's Representative (COR) for this contract:
Mr. James McMahon

Federal Student Aid
Suite 11lGS
Email: james.mcmahon@ed.gov
Phone: (202) 377-3124
N. Additional Terms:
1. The Title IV Servicing contracts are for any potential services to manage all types of Title
IV student aid obligations, including, but not limited to, servicing and consolidation of
outstanding debt. However, they are not Requirements contracts.
2. Each contractor will provide, at a minimum, the services provided within their proposal,
in accordance with the pricing identified in Term #3 below.
3. The Government will set and manage the common pricing, including tier structure,
below:
Status Volume Low Volume Hie:h Unit Price

Borrowers in In-school Status NIA NIA $ 1.050
Bmniwen, in Grace or Current Repayment
Status 1 3,000,000 $ 2.110
3,000,001 UP $ 1.900
Borrowers in Deferment or Forhearance 1 1.600.000 $ 2.070
1.600.001 UP $ 1.730
Bo1rowers 31-90 Days Delinquent NIA NIA $ 1.620
Borrowers 91-150 Davs Delinuuent NIA NIA $ 1.500
Borrowers 151-270 Davs Dclinaucnt NIA NIA $ 1.370
Borrowers 270+ Davs Delinuuent NIA NIA $ (l.500
Out year pricing will follow the methodology described utilizing the subsequent tenns.
There will be no set declination in pricing at the time of award.
4. The Government has included an escalation methodology based upon the Bureau of
Labor Statistics' (BLS) Employment Cost Index (ECI) for Total Compensation, Private
Industry, Service Occupations (Not Seasonally Adjusted), to account for significant
inflation and/or deflation. When the ECI exceeds 3.0% (plus or minus) in any given year
the Government will adjust the established common pricing by any amount in excess of
this rate. The calculated rate of escalation will equal the average of the 12-month percent
change for the previous four quarters, ending June 30 th . This ECI escalation will be
applied beginning in September of the same calendar year. Further, this escalation will
compound for all remaining years of the Base and Optional Ordering Periods.
For example. ECI rate released in June 2010 is 3.6%. The Government will increase unit
pricing by .6% for the contract beginning September 1, 2010 and all remaining years of
the Base Ordering Period, as well as the Optional Ordering Period.
A decreasing rate of inflation would follow the same pattern as above. For example. if the
ECI decreases by more than 3.0%, then the unit prices for the remaining out-years will
also decrease by the percentage in excess of 3.0°/41.For example, ECI rate released in
June 2010 is -4.2%. The Government will decrease unit pricing by 1.2% for the contract
period beginning September 1, 2010 and all remaining years of the Base Ordering Period.
as well as the Optional Ordering Period.
5. Common pricing includes all supplies, services and other costs to deliver Title IV
servicing under this contract, including:
• Costs for bringing contractor systems into compliance for handling federally held
debt.
• Costs for legislative. regulatory or policy changes that affect the FFEL community as
a whole, as is commercially accepted practice in the FFEL community.
• For all other costs, the Department and the contractor(s) may come to an agreement
via change order process or negotiation, as necessary.
6. The Government makes no guarantee to any contractor that their organization will retain
their current loan servicing volume. In addition, the Government makes no minimum
Solicitation \lumber: PSA-TitlelV-09 Page 11 of20
volume guarantees to any contractor. The Government does guarantee a minimum

dollar/revenue amount of $5,000,000 over the base ordering period under this Indefinite
Delivery, Indefinite Quantity contract, regardless of the number of loans serviced by a
contractor.
7. The Government reserves the right to periodically review and equitably adjust the rate
structure to maintain effectiveness of the services provided (i.e., different volume breaks,
different ties, cost allocations, etc)
8. The Government reserves the right to equitably introduce, eliminate, or modify loan
deliverables/status items that are in the best interest of the Government or Borrower. (i.e.,
in-school deferments moved into the In-School deliverable; new deferment or
forbearance categories: etc).
9. The Government reserves the right to unilaterally shift borrowers in the best interest of
the Government or Borrowers, at no additional cost to the Government. It is anticipated
that this will be done only with reasonable and prudent cause.
10. The Government retains the unilateral right to resolve split-borrowers as deemed
appropriate by the Government, at no additional cost to the Government.
B.14 52.212-5 Contract Terms And Conditions Required To Implement Statutes Or

Executive Orders-Commercial Items (Dec 2008)
(a) The Contractor shall comply with the following Federal Acquisition Regulation (FAR)
clauses, which are incorporated in this contract by reference, to implement provisions of law
or Executive orders applicable to acquisitions of commercial items:
(I) 52.233-3. Protest Alier Award (Aug 1996) (31 U.S.C. 3553).
(2) 52.233-4. Applicable Law for Breach of Contract Claim (Oct 2004) (Pub. L. 108-77. 108-
78)
(b) The Contractor shall comply with the FAR clauses in this paragraph (b) that the Contracting
Officer has indicated as being incorporated in this contract by reference to implement
provisions of law or Executive orders applicable to acquisitions of commercial items:
_x (I) 52.203-6, Restrictions on Subcontractor Sales to the Government (Sept 2006), with
Alternate I (Oct 1995) (41 U.S.C. 253g and 10 U.S.C. 2402).
_x (2) 52.203-13, Contractor Code of Business Ethics and Conduct (Dec 2008) (Pub. L. 110
252, Title VI, Chapter I (41 U.S.C. 251 note)).
_ (3) 52.219-3, Notice of Total HUBZone Set-Aside (Jan 1999) (15 U.S.C. 657a).
_ (4) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concerns
(July 2005) (if the offeror elects to waive the preference, it shall so indicate in its offer)
( 15 U.S.C. 657a).
_ (5) [Reserved]
_ (6)(i) 52.219-6, Notice of Total Small Business Set-Aside (June 2003) (15 U.S.C. 644).
_ (ii) Alternate I (Oct 1995) of 52.219-6.
_ (iii) Alternate II (Mar 2004) of 52.219-6.
_ (7)(i) 52.219-7, Notice of Paitial Small Business Set-Aside (June 2003) (15 U.S.C. 644).
_ (ii) Alternate I (Oct 1995) of 52.219- 7.
_ (iii) Alternate II (Mar 2004) of 52.219-7.
_x (8) 52.219-8, Utilization of Small Business Concerns (May 2004) (15 U.S.C. 637(d)(2) and
(3)).
~ (9)(i) 52.219-9. Small Business Subcontracting Plan (Apr 2008) (15 U.S.C. 637(d)(4)).
_ (ii) Alternate I (Oct 200 I) of 52.219-9.
_X (iii) Alternate II (Oct 200 I) of 52.219-9.
_ ( !0)52.219-14, Limitations on Subcontracting (Dec 1996) (15 U.S.C. 637(a)(l4)).
_ (11 )52.219-16, Liquidated Damages-Subcontracting Plan (Jan 1999) (15 U.S.C.
637(d)(4 )(F)(i)).
_ (12) (i) 52.219-23, Notice of Price Evaluation Adjustment for Small Disadvantaged
Business Concerns (Oct 2008) (10 U.S.C. 2323) (if the offeror elects to waive the
adjustment, it shall so indicate in its offer).
_ (ii) Alternate I (June 2003) of 52.219-23.
_ (13)52.219-25, Small Disadvantaged Business Participation Program-Disadvantaged Status
and Reporting (Apr 2008) (Pub. L. 103-355, section 7!02, and 10 U.S.C. 2323).
_ (14 )52.219-26, Small Disadvantaged Business Participation Program- Incentive
Subcontracting (Oct 2000) (Pub. L. 103-355. section 7102. and 10 U.S.C. 2323).
_ (15)52.219-27, Notice of Total Service-Disabled Veteran-Owned Small Business Set-Aside
(May 2004) (15 U.S.C. 657 t).
_ (16) 52.219-28, Post Award Small Business Program Rerepresentation (June 2007) (15
U.S.C. 632(a)(2)).
~ ( 17) 52.222-3, Convict Labor (June 2003) (E.O. 11755).
_x ( 18) 52.222-19, Child Labor-Cooperation with Authorities and Remedies (Feb 2008) (E.O.
13126).
_x (l 9) 52.222-2 l. Prohibition of Segregated Facilities (Feb 1999).
~ (20) 52.222-26. Equal Opportunity (Mar 2007) (E.O. 11246).
_x (21) 52.222-35. Equal Opportunity for Special Disabled Veterans. Veterans of the Vietnam
Era, and Other Eligible Veterans (Sept 2006) (38 U.S.C. 4212).
_x (22) 52.222-36. Affirmative Action for Workers with Disabilities (Jun 1998) (29 U.S.C.
793).
_x (23) 52.222-37. Employment Reports on Special Disabled Veterans. Veterans of the Vietnam
Era, and Other Eligible Veterans (Sept 2006) (38 U.S.C. 4212).
_x (24) 52.222-39. Notification of Employee Rights Concerning Payment of Union Dues or
Fees (Dec 2004) (E.O. 13201).
_x (25) (i) 52.222-50, Combating Trafficking in Persons (Aug 2007) (Applies to all contracts).
_ (ii) Alternate I (Aug 2007) of 52.222-50.
_ (26) (i) 52.223-9, Estimate of Percentage of Recovered Material Content for EPA-
Designated Items (May 2008) (42 U.S.C. 6962(c)(3)(A)(ii)).
_ (ii) Alternate I (May 2008) of 52.223-9 (42 U.S.C. 6962(i)(2)(C)).
_ (27) 52.223-15, Energy Efficiency in Energy-Consuming Products (Dec 2007) (42 U.S.C.
8259b).
_ (28) (i) 52.223-16, IEEE 1680 Standard for the Environmental Assessment of Personal
Computer Products (Dec 2007) (E.O. 13423).
_ (ii) Alternate I (Dec 2007) of 52.223-16.
_ (29) 52.225-1, Buy American Act-Supplies (June 2003) (41 U.S.C. IOa-l0d).
_ (30) (i) 52.225-3. Buy American Act-Free Trade Agreements-Israeli Trade Act (Aug
2007) (41 U.S.C. IOa-lOd, 19 U.S.C. 3301 note, 19 U.S.C. 2112 note, Pob. L 108-
77, 108-78, l08-286, 109-53 and l09-169).
_ (ii) Alternate I (Jan 2004) of 52.225-3.
_ (iii) Alternate II (Jan 2004) of 52.225-3.
_ (31) 52.225-5, Trade Agreements (Nov 2007) (19 U.S.C. 2501, et seq., 19 U.S.C. 3301 note).
_x (32) 52.225-13, Restrictions on Certain Foreign Purchases (June 2008) (E.O. 's,
proclamations, and statutes administered by the Office of Foreign Assets Control of the
Department of the Treasury).
_ (33) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (Nov 2007) (42 U.S.C.
5150).
_ (34) 52.226-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (Nov
2007) (42 u.s.c. 5150).
_ (35) 52.232-29, Terms for Financing of Purchases of Commercial Items (Feb 2002) (41
u.s.c. 255([), 10 u.s.c. 2307([)).
_ (36) 52.232-30. Installment Payments for Commercial Items (Oct 1995) (41 U.S.C. 255(1),
lO U.S.C. 2307(1)).
_x (37) 52.232-33, Payment by Electronic Funds Transfer-Central Contractor Registration
(Oct 2003) (31 U.S.C. 3332).
_ (38) 52.232-34, Payment by Electronic Funds Transfer-Other than Central Contractor

Registration (May 1999) (31 U.S.C. 3332).
_ (39) 52.232-36, Payment by Third Party (May 1999) (31 U.S.C. 3332).
_x (40) 52.239-1, Privacy or Security Safeguards (Aug 1996) (5 U.S.C. 552a).
_ (41) (i) 52.247-64, Preference for Privately Owned U.S.-Flag Commercial Vessels (Feb
2006) (46 U.S.C. Appx. l241(b) and 10 U.S.C. 2631).
_ (ii) Alternate I (Apr 2003) of 52.247-64.
(c) The Contractor shall comply with the FAR clauses in this paragraph (c), applicable to
commercial services. that the Contracting Officer has indicated as being incorporated in this
contract by reference to implement provisions of law or Executive orders applicable to
acquisitions of commercial items:
...K(I) 52.222-41, Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351, et seq.) .
...K(2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C. 206
and 41 U.S.C. 351. et seq.).
_x (3) 52.222-43, Fair Labor Standards Act and Service Contract Act-Price Adjustment
(Multiple Year and Option Contracts) (Nov 2006) (29 U.S.C. 206 and 41 U.S.C. 351, et
seq.).
_ (4) 52.222-44, Fair Labor Standards Act and Service Contract Act-Price Adjustment (Feb
2002) (29 U.S.C. 206 and 41 U.S.C. 351, et seq.).
_ (5) 52.222-51, Exemption from Application of the Service Contract Act to Contracts for
Maintenance, Calibration, or Repair of Certain Equipment-Requirements (Nov 2007)
(41 U.S.C. 351. et seq.).
_ (6) 52.222-53, Exemption from Application of the Service Contract Act to Contracts for
Certain Services-Requirements (Nov 2007) (41 U.S.C. 351, et seq.).
_ (7) 52.237-11, Accepting and Dispensing of$! Coin (Sept 2008) (31 U.S.C. 5112(p)(I)).
(d) Comptroller General Examination of Record. The Contractor shall comply with the
provisions of this paragraph (d) if this contract was awarded using other than sealed bid, is in
excess of the simplified acquisition threshold, and does not contain the clause at 52.215-2,
Audit and Records-Negotiation.
( 1) The Comptroller General of the United States, or an authorized representative of the
Comptroller General, shall have access to and right to examine any of the Contractor's
directly pertinent records involving transactions related to this contract.
(2) The Contractor shall make available at its offices at all reasonable times the records,
materials, and other evidence for examination, audit, or reproduction, until 3 years after
final payment under this contract or for any shmter period specified in FAR Subpart 4.7,
Contractor Records Retention, of the other clauses of this contract. If this contract is
completely or partially terminated, the records relating to the work terminated shall be
made available for 3 years after any resulting final termination settlement. Records
relating to appeals under the disputes clause or to litigation or the settlement of claims
arising under or relating to this contract shall be made available until such appeals,
litigation, or claims are finally resolved.
(3) As used in this clause, records include books, documents, accounting procedures and
practices, and other data, regardless of type and regardless of form. This does not require
the Contractor to create or maintain any record that the Contractor does not maintain in
the ordinary course of business or pursuant to a provision of law.
(e) (1) Notwithstanding the requirements of the clauses in paragraphs (a), (b), (c), and (d) of this
clause, the Contractor is not required to flow down any FAR clause, other than those in
paragraphs (e)( I )(i) through (xi) of this paragraph in a subcontract for commercial items.
Unless otherwise indicated below, the extent of the flow down shall be as required by the
clause-
(i) 52.203-13, Contractor Code of Business Ethics and Conduct (Dec 2008) (Pub. L.
110-252, Title VI, Chapter I (41 U.S.C. 251 note)).
(ii) 52.219-8, Utilization of Small Business Concerns (May 2004) (15 U.S.C. 637(d)(2)
and (3)), in all subcontracts that offer further subcontracting oppottunities. If the
subcontract (except subcontracts to small business concerns) exceeds $550,000
($1,000,000 for construction of any public facility), the subcontractor must include
52.219-8 in lower tier subcontracts that offer subcontracting opportunities.
(iii) 52.222-26, Equal Oppmtunity (Mar 2007) (E.O. 11246).
(iv) 52.222-35, Equal Oppottunity for Special Disabled Veterans, Veterans of the
Vietnam Era, and Other Eligible Veterans (Sept 2006) (38 U.S.C. 4212).
(v) 52.222-36, Affirmative Action for Workers with Disabilities (June 1998) (29
u.s.c. 793).
(vi) 52.222-39, Notification of Employee Rights Concerning Payment of Union Dues
orfees(Dec2004)(E.O.13201).
(vii) 52.222-41. Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351. et seq.).
(viii) 52.222-50, Combating Trafficking in Persons (Aug 2007) (22 U.S.C. 7104(g)).
Flow down required in accordance with paragraph (t) of FAR clause 52.222-50.
(ix) 52.222-51, Exemption from Application of the Service Contract Act to Contracts
for Maintenance, Calibration, or Repair of Certain Equipment-Requirements (Nov
2007) (41 U.S.C. 351, et seq.).
(x) 52.222-53, Exemption from Application of the Service Contract Act to Contracts
for Certain Services-Requirements (Nov 2007) (41 U.S.C. 351, et seq.).
(xi) 52.247-64, Preference for Privately Owned U.S.-Flag Commercial Vessels (Feb
2006) (46 U.S.C. Appx. 124l(b) and 10 U.S.C. 2631). Flow down required in
accordance with paragraph (d) of FAR clause 52.247-64.
(2) While not required, the contractor may include in its subcontracts for commercial items a
minimal number of additional clauses necessary to satisfy its contractual obligations.
C. STATEMENT OF OBJECTIVES (SOO)
C.1 General Description Of Scope/Purpose

C.1.1 Federal Student Aid Background/Overview
Federal Student Aid (FSA), an office of the Department. plays a central and essential role
in America's postsecondary education community.
FSA's core mission is to ensure that all eligible individuals benefit from federal financial
assistance-grants, loans and work-study programs-for education beyond high school.
The programs FSA administers comprises the nation's largest source of student aid:
during the 2007-08 school year alone, FSA provided approximately $83 billion in new
aid to nearly 10 million postsecondary students and their families. FSA' s staff of 1,100 is
based in 10 cities, in addition to its Washington, D.C. headquarters.
C.1.2 Current Need
With the current economic and liquidity uncertainty facing financial markets, many
student loan lenders are dropping out of the market. With more than $65 billion in 2008-
09 loans and approximately $ t 30 billion in eligible 2003-07 student loans on bank
balance sheets and auction rate securitizations, the capital markets are currently unable to
generate adequate funds at prices that will ensure 2009-10 loans can be made.
Recent legislation including the College Cost Reduction Authorization Act of 2008
(CCRAA) (Pub. Law 1 l 0-84) and the Ensuring Continued Access to Student Loans Act
of 2008 (ECASLA) (Pub. Law l 10-227) enabled the Department to accept former
Federal Family Education Loan Program (FFELP) loans in the form of additional Direct
Loan (DL) capacity, and to purchase FFELP loans as far back as 2003, in an effort to
bring liquidity and stability back to the student loan market.
With the sudden increase in current and potential loan volume that the Department will
be responsible for servicing, the need for increasing the Title IV student aid servicing
vehicles is determined appropriate at this time.
C.1.3 Objective
Acquire efficient and effective commercial contract services to manage all types of Title
IV student aid obligations, including, but not limited to, servicing and consolidation of
outstanding debt.
C.1.4 Constraints
C.1.4.lSpecific compliance activities for servicing Federally held assets include,
but are not limited to, Attachments A-l through A-3 provided herein.
C.1.4.2In order to manage the costs associated with such a potentially large
portfolio, the service must provide innovative measures to ensure portfolio
growth is not the key driver of total cost. Contractor incentives must be
based on performing assets, rather than transaction or activity based
delinquency incentives. Costs may also be managed through redistribution
of customers to self-service options, as approved by the Government.
Performance measures will help ensure that the complete service operates
as efficiently and effectively as possible and that it is achieving the desired
business outcomes. These measurements will be flexible to allow for

regular reviews and revisions as necessary.
C.1.4.3The contractor(s) will be responsible for maintaining a full understanding
of all federal and state laws and regulations and FSA requirements and
ensuring that all aspects of the service continue to remain in compliance as
changes occur.
C.1.4.4The contractor(s) will provide a service flexible enough to handle new
requirements generated by Congress and respond to legislative mandates
and policy changes. Please see Appendix A - Standards and Relevant
Documents for historical and cmTent representative information.
C.1.4.SThe contractor(s) will provide timely (as defined by FSA and contractor)
responses to Office of Inspector General (OIG), General Accounting
Office (GAO), budget, data, and management requests.
C.1.4.6 It is understood and mutually agreed that the Department of Education
has exclusive ownership of all information stored in, retrieved, modified,
and/or archived in as part of this service. The contractor shall have no
rights in such information and no rights to such information shall vest on
the contractor by virtue of its performance of this contract. No other party
has the right to copy, delete, archive, or transfer such information without
the prior express written consent of the Department of Education. The
contractor shall not use such information for any marketing or solicitation
purpose including, but not limited to, commercial adve11ising, credit
offers, or similar campaigns.
C.2 Attachments/Supplemental Documents

Number Title
A-I Additional Servicer-Initial Requirements Document (Version 21.0)
A-2 Additional Servicer-Intermediate Requirements Document (Version
60)
A-3 Additional Servicer-Full Requirements Document (Version 6.0)
A-4 Ongoing Allocation Methodoloo-v
A-5 Sample-Ongoing Allocation Metric Calculation
A-6 Servicing Pricing Definitions (Version 9.0)
Solicitation \lumber: PSA-TitlclV-09 Page 20 of 20
All_lnitiaIReq_v21.0.doc
AII_Initia!Req_v2 l .O
Additional Servicer - Initial Requirements

Required by 8/31/09 unless otherwise noted
TABLE OF CONTENTS
General Statement .................................................................................................................

3
Financial Reporting ................................................................................................................

3
Treasury ..................................................................................
.. .5
Transaction Management. ...............................................

.. .6
Internal Controls .....................................................................................................................

7
Accounting ..............................................................................................................................
9
Reconciliations .......................................................................................................................
9
Additional Reporting ............................................................................................................

12
Security ....................................................................................................................................
12
NSLDS ....................................................................................................................................
13
Unique Client/Lender Requirements for Federally Serviced Portfolio ...........14
Loan Conversion ...................................................................................................................

16
AII_Initia!Req_v2 l .O 2
General Statement
It is the intent of the Department to procure a performance-based contract(s) that
promotes competition and provides best of business services. To achieve this goal, the
Department expects each servicerto provide commerciallyavailable servicesthat will
yield high performing portfolios and high levels of customer satisfaction. The following
statements apply:
Servicers will be required to meet all statutory and legislative requirements.

Servicerswill use their own discretionin decidingto provide services or business
functionality that is recommended but not required.
Servicers may leverage all borrower repayment channels while maintaining existing
branding provided all federally held loans are clearly distinguished and identified,
and borrowers are directed to make payment directly to the Department via a U.S.
Treasury lockbox or electronic payment service.
Small differences due to rounding in various calculations are understood and
accepted providing the calculation itself is in compliance with federal regulation.
The Department will allocate volume based on defined and understood performance
metrics.
The Department does not intend to provide additional service level requirements.
The Department does, however, expect best of business practices to be deployed.
The Department will not require the use of the Department or FSA logo on letters,
web sites, etc.
Servicers will have full discretion to promote or not promote services as long as they
meet legislative and regulatory requirements and are cost neutral to the
Government.
Servicers will have discretion to provide services to schools.
Servicers may use their own authentication process as long as the process is fully
compliant with federal IT security guidelines.
With regard to split borrowers, it is acceptable for servicers to handle requests,
phone calls, etc. for all loans being serviced by that servicer, regardless of the holder
(Federal or Non-Federal), as long as all federal laws and regulations are met.
Financial Reporting
1. The servicer shall uniquely identify each specific activity (e.g., Collection of Principal,
Collection of Interest, etc.) in the transaction level data.
2. The servicer shall provide required accounting reports. A preliminary list is presented
below.
a) Trial Balance by Fund & a Working Trial Balance By Fund
b) Detailed Trial Balance by Transaction Type
c) Sub ledger Reconciliation Reports
d) Transaction Tables and mapping (Crosswalk) to the Department's general ledger
system, the Financial Management System (FMS), including transaction
descriptions and amount fields.
e) Cash Receipt Detail
f) Cash Disbursement Detail
g) Report of Debts Assigned by Assignor (Lender, GA, Intra-Fund Transfers)
h) Report of Loans Consolidated (by Fund, Cohort Year, Loan Program Type, Risk
Category)
i) Report of Loans Rehabilitated (if applicable)
j) Loan portfolio performance reports (by Fund, Loan Type, cohort year and risk
category).
k) Collection Activity Report - The report summarizes by Current Month, Current
Quarter, and Year to Date for each Loan Type, the number of loans and the
amount of loans for each delinquency stage.
I) Loans Transferred to and from the Department's Default Management Collection
System (DMCS)- The report has 3 parts:
a. Loans Transferred to DMCS - Displays by transfer date the total

number of borrowers, total number of loans, total principal balance
at time of transfer, and date DMCS accepts the loans for each
weekly transmission to DMCS.
b. Rejected and Re-transfer to DMCS - Displays by re-transfer date
the total number of loans, total number of borrowers, total principal
balance, and date DMCS accepts the loans for each weekly
transmission to DMCS.
c. Transfers by Loan Type - Displays by transfer date, total number of
borrowers, and total number of PLUS, Stafford, and Consolidation.
m) DMCS Recall and Rehabilitation Tracking Report - The report displays by
month/year the total number of borrowers recalled from DMCS, total number of
loans recalled, total number of Rehabilitated loans and borrowers received from
DMCS.
n) System Balancing Reporting of daily, weekly and monthly activity sent and
received with each interfacing partner at the Batch level and at the Transaction
Type, Transaction Count, Transaction Amount levels. Reports activity sent and
activity received; and balances activity received to activity accepted and rejected.
o) Financial Transactions Reconciliation Report of all daily, weekly and monthly
transactions posted on the servicing system for each interfacing partner.
Displays summary data by financial transaction type, number, and dollar
amounts.
p) Work in Process Reports of activity received and accepted into the servicing
system, but not posted to borrower accounts for each interfacing partner.
Displays detail level transactions at the loan level for all financial transactions
received but not posted. Includes applicable dollar amounts and reflects aging of
each transaction. Reporting can include, but is not limited to, pending
disbursements, loan adjustments, consolidation payoffs, etc. (See below for
specific unapplied cash reporting). Daily cumulative reporting with the last daily
report for the month reflecting the WIP balances as of month end.
q) Unapplied Cash Payment Recycle report: Payment and Payment adjustment
activity received and accepted into the servicing system but not posted to
borrower accounts. Reporting is by payment source (including, but not limited
to: lockbox, electronic debit, IPAC, etc.) Displays detail level cash payment and
payment return/adjustment transactions at the borrower level and includes
Treasury document information(schedule number, schedule amount and

schedule type) and aging of each transaction. Daily cumulative reporting with the
last daily report for the month reflecting the WIP balances as of month end.
r) Ad-hoc reporting capability and access for the Department (see
"Reconciliations").
Treasury
3. The servicer shall require entities making payments on Government loans
(borrowers, lenders, etc) to direct payments to a Treasury designated service
including:
a) Treasury lockbox
b) Pay.gov
c) Remittance Express
d) IPAC.
Note: Receipts must be processed in accordance with guidance provided in
Treasury Financial Management (TFM), available at
www.fms.treas.gov/tfmlindex.htm
4. The servicer shall establish an interface with the Treasury lockbox service for the
receipt of payment posting file and returned payments files.
5. The servicer shall establish an interface with Pay.gov for the receipt of ACH debits
and credit card payments.
6. The servicer shall establish an interface for Remittance Express (REX) to support
receipt of ACH credits. REX provides FSA and the servicer with download capability
of an activity file with optional fields for identifying borrower accounts.
7. The servicer shall establish an interface for the receipt and processing of Inter-
Governmental Payment and Collection (IPAC) systems payments. IPAC provides
FSA and the servicer with download capability of an activity file with optional fields
for identifyingborroweraccounts.
8. The servicer shall post payments to the borrower accounts on the same date of
receipt of payment information from Treasury. If the servicer directly receives
payments, those payments will be deposited to Treasury on the day of receipt.
9. The servicer shall maintain a recycle or unapplied file of any payment/payment
returntransactionsthat cannot be posted to a borroweraccount. The servicer shall
perform due diligence to research payments held in suspense for the purpose of
resolving the unpasted items including: posting payment to appropriate borrower
account;refundingto remitter;or escheatmentto Treasury.
10. The servicer shall obtain daily deposit information from Treasury's Ca$hlinkll
system to support accounting processes and controls, such as daily and monthly
reconciliations.
11. The servicer shall maintain proper controlsover payment postingand accounting
activities,and perform daily and monthlyrequired reconciliations.
12. Issuance of Refunds - The servicer shall promptly manage credit balance accounts,
and other payments and accounts requiring a refund. The Servicer shall process
refund transactionsto borrowers(borroweroverpayments),lenders (such as
consolidation overpayments), etc.
a) The servicer shall establish an interface and process payments refunds via
interface via interface with FSA's Financial Management System (FMS) using the
FMS standard file format (see FMS Attachment A).
b) Batches of refunds shall be subject to FSA review and approval.
c) The servicershall receive and work from a Treasury ConfirmationReport
available through Treasury's Government-Wide Accounting System (GWA). This
confirmation data will be used to provide information to borrower inquiries on
refund status. The GWA report confirms the completion of processing on a
batch, and provides the first and last check number for the batch.
d) The servicershall receive a reportof Treasury Cancellations,maintain
cancellation data, and shall provide information for borrower inquiries and
support re-issuance of refunds.
e) The servicer shall perform due diligence on cancelled refunds, on issuance of
validated refunds, and will follow Treasury guidelines for escheatment.
f) The servicer shall request FSA to cancel refunds, when appropriate.
g) The servicer shall use FSA's student application internet gateway (SAIG) to
transmit refund requests to FMS.
h) The servicer shall pass Treasury cancellation data to FMS using the FMS
standard file format (see FMS Attachment A).
Transaction Management
13. The servicer shall establish a system and processes to correctly record all
transactions on their database and to post summary transactions to the FSA's
general ledger (FMS) on the same business day they are generated.
14.AII servicer transactions shall include all fields as required by FMS and all amounts
applicable to each transaction type.
15.AII servicer transactions must pass all FMS edits for posting into the general ledger.
16. The servicer shall ensure all transactionsare reversible.
17. The servicer shall provide unique transaction reporting for each type of loan activity.
18.AII servicer transactions will be accurately translated (mapped) from the Servicer's
subsidiary ledger to FSA's general ledger (FMS).
19. The servicer shall maintain both the posting date and effective date of the
transactionson their system.
20. The servicer shall provide an audit trail that efficiently links their detailed transactions
in the subsidiary ledger to summarized transactions in FSA's general ledger.
Transactionsmust have sufficientaudit trail to supportefficienttracing.
21. The servicer shall include original Treasury document numbers on applicable
transactions, in addition to any system created document numbers (including but not
limited to: SF215, SF5515, SF1166, SF1098, and SF1081 ). The usage of Treasury
documents is described on the web site http://fms.treas.gov/index.html.
22. The servicer shall assign and retain the Credit Reform Code (CRC), recording and
reporting on all loan related transactions at the CRC level. Federal Credit Reform
Act legislation and Treasury guidelines for reporting are described on the web site
http://fms.treas.gov/index.html. Appendix A (CRC Codes) of Attachment C (FMS File
Layouts) describes how CRC codes are generated.
Internal Controls
23. The servicer shall incorporate a system of internal controls consistent with federal
laws, regulations,policiesand authoritativeguidance. These laws, regulations,and
guidances include, but are not limited to: Federal Financial Management
Improvement Act (FFMIA); Federal Managers' Financial Integrity Act (FMFIA); CFO
Act: Government Performance and Results Act (GPRA): GAO's Green Book; 0MB
Circulars A-123, 1-127, and A-130; Joint Financial Management Improvement
Program (JFMIP); and Treasury Financial Manual (TFM).
24. The servicer's procedures and systems shall include a system of internal controls
that ensures resource use is consistentwith laws, regulationsand policies;
resourcesare safeguarded againstwaste, loss, and misuse;and reliabledata are
obtained, maintained, and disclosed in reports. Appropriate internal controls shall be
applied to all system inputs, processing and outputs.
Examples of Internal Control Standards to be implemented by the servicer include
the following:
a) Review and Reconciliation: Records are examined and reconciled to determine
that transactions were properly processed and approved.
b) Execution of Transactions: Independent evidence is required to be maintained to
ensure that authorizationsare issued by personsacting withinthe scope of their
authority and transactions conform with such authority.
c) Segregation of Duties: Proper segregation of duties is required to exist among
functionsincluding:authorization,execution,recordingand reviewing
transactions,custodyof assets, and performingreconciliations.
d) Qualified and continuous supervision is required to be provided to ensure that
proper internal control is maintained.
e) Access to and Accountability for Resources: Access to resources and custody
and use of resourcesis requiredto be assigned and maintained.
25. The servicer shall provide FSA with supporting documentation for FSA's 0MB
Circular A-123 annual review, the annual Financial Statement Audit, and other audits
and reviews (as further described in the Requirement #29 below on Audit Support
Services and in Audit Attachment A, "Audit Support Requirements").
26. The servicer shall consult with FSA during FSA's 0MB Circular A-123 annual review
process and for other audits, so that FSA can: (a) maintain its understanding of the
servicers controls (in the context of GAO Internal Control Standards and the
Committee on Sponsoring Organizations (COSO) control framework), (b) maintain
FSA documentation depicting the servicer's controls and process flows (as further
described in Requirement #29 below on Audit Support Services and in the
attachment, "Audit Support Requirements"), and (c) maintain FSA's test plan, which
will call for the provision of supporting materials from the servicer.
27. The servicer shall be responsible for resolving all deficiencies identified during audits
and participatingin correctiveaction plans as needed.
28. The servicer shall provide FSA with support for conducting FSA site visits to servicer
centers of operation. The purpose of the site visits will be to enable and enhance
FSA's plans for the conduct of its A-123 review. In addition, during the site visit, FSA
will observe the execution of selected processes for compliance with stated
proceduresand system function.
29. The servicer shall provide Audit Support Services, upon request, including but not
limited to the following audits and reviews. The "Audit Support Requirements"
documentattached providesadditionalinformationon the annual Financial
Statement Audit and describes the "Prepared by client" (or PBC) process that will be
used by the auditor and/or FSA to submit requests for documentation, data, and/or
walkthroughs and for the servicer to fulfill these requests.:
a) FSA's annual Financial Statement audits:
b) Assessments of internal controls in accordance with FMFIA and 0MB Circular A-
123, Appendix A;
c) Program-specific financial and compliance audits conducted by GAO, OIG,
and/or 0MB;
d) FISMA audits;
e) Certification and Accreditation reviews;
f) Internal reviews;
g) Contract oversight activities: and
h) Agreed Upon Procedures Audits for Loan Purchase Programs.
Thissupportgeneraffyincludes,but is not limitedto: makingresourcesand facilities
available, participating in audit planning (such as to determine when resources would be
made available and for whatpurpose), respondingto "prepared-by-client"(PBC)
requests,reportingstatus,and remediatingdeficienciesidentified.At a minimum,PBC
requestswiffinclude:interviews,access to process and system documentation,standard
and ad hoc queriesand reports,and general questionson processes,systems,data,
and/or other matters.
30. The servicer shall meet requirements for a Type II SAS 70 audit. It is anticipated that
performance of the Type II SAS 70 audit with an unqualified opinion and submission
of the resulting work papers will eliminate or substantially reduce audit work
performed by various auditors, internal and external to the Department, as part of
the Department-wide and Government-wide annual audits. As part of their contracts
with various lenders, servicers also normally have a SAS 70 audit performed
annually by a qualified independent auditor.
a) For IT controls, the servicer shall supplement the Type II SAS 70 with
additionalagreed-upon proceduresresultingin an audit consistentwith
GAO's Federal Information System Control Audit Manual (FISCAM). The
results of these procedures should be conducted and reported at least
annually, with a year-end of 6/30. Further, the servicer shall provide FSA
with a "bridge letter" covering the period from 6/30 to 9/30 indicating no
changes to the control environment.
b) For operational controls, the servicer shall ensure that the Type II SAS 70
covers all GAO Internal Control Standards or COSO Components (e.g.,
controlenvironment,risk assessment,controlactivities,informationand
communication, and monitoring) for those transactions processed by the
servicer. The results of these procedures should be conducted and
reported at least semi-annually covering the periods 1/1 - 6/30 and 7/1 -
12/31.
Accounting
31. The servicer shall create a financial interface between the FSA servicer and FSA
Financial Management System (FMS) to provide financial data to FMS on a daily,
weekly and monthly basis.
a) The data and data layouts to be provided within this interface are described in
the FMS Attachment C - FMS File Layouts
b) Submission/ send rules for these transmissions are:
1. In addition to daily transaction files, servicer shall send weekly (summary) and
monthly (interest and adjustment) files to FMS.
2. Servicer shall use secure FSA's SAIG mailbox to place daily, weekly and
monthly files on the FMS server for processing in FMS.
32. The servicer shall conductaccountancy,ensuringthat transactionsof the servicer's
subsidiary ledger are accurately recorded in the FMS general ledger, to include:
a) Managing the accounting transaction processing between the subsidiary ledger
and the general ledger.
b) Preparing proceduralinstructionsand executionof manual proceduresrelated to
the preparationof accountingtransactions.
c) Reconciling cash, accounts receivable, accounts payable, and other general
ledger accounts.
d) Correcting all differences between the subsidiary ledger balances and the control
account balances in the general ledger.
e) Assisting FSA, FMS, and CFO in posting financial data and recommending
alternativesto resolve rejected activityand variances.
Reconciliations
33. The servicer shall perform reconciliations of balances and activity as requested, that
meet the followinggeneral requirements:
a) Reconciliation activity should demonstrate that all required data is transmitted to
the Department and that all omissions, duplications of data, and recording errors
are detected and corrected timely.
b) All reconciliationsand financialaccountingwill be inclusiveof principal,interest
and fee amounts.
c) Monthly reconciliation between Servicing Trial Balance by Portfolio and FSA's
general ledger (FMS) trial balance for each individual balance sheet account
(balances and activity).
d) All programs are to be accounted, reported and reconciled individually (distinct
portfolios).
e) Portfolio balances must be supportable at the loan level.
f) Unless otherwise instructed, all reconciliation processes must identify and define
specifictransactionscausingdifferences.
g) Unless otherwise instructed, all requirements apply to each portfolio.
h) Monthly reconciliations are due to FSA by the 8th calendar day of the subsequent
month. (e.g. Reconciliations for the month of June are due July 8th .)
i) Monthly reconciliations require contractor review by at least one level of
management.
j) Monthlyreconciliationsrequire the signatureof the preparer and reviewer and

the date of signatures.
k) Signed monthly reconciliations and all necessary supporting documentation are
to be provided to FSA in Adobe .pdf format.
I) The servicer shall provide reports in the file format requested by FSA. File format
types would include, but are not limited to: the Microsoft Office Professional Suite
(Excel, Word, Access, etc.), Adobe (.pdf), text (.txt), comma delimited (.csv) etc.
m) Daily reconciliations are not standard deliverables to FSA but are considered
operationalprocessesand subjectto internalcontroltesting.
n) Unless otherwise instructed,all reconcilingitems arisingfrom monthly
reconciliations are to be researched and cleared within the month subsequent to
the reconciled period. For example, reconciling items for the month of June must
be cleared withinJuly. This eliminates repeat reconcilingitems.
o) Unless otherwise instructed,all reconcilingitems arisingfrom daily reconciliations
are to be researched and cleared within 48 hours.
p) Daily reconciliations include tracking and resolution of all work in process activity.
34. The servicer shall reconcile loan sales as follows:
a) Perform daily 3-way reconciliation between invoice (pre-sale report), Bill of Sale
from selling lender, and conversion reports from servicing system. Offeror must
be able to produce the reconciliation at the deal, invoice, lender and summary
level.
b) Perform daily and monthly over/underpayment reconciliation between the Selling
lender, servicing system, FMS and Treasury.
c) Maintain resulting accounts receivable/accounts payable reconciliation of
over/underpayment activity between the Selling lender & FMS. To include:
1. Maintain balance of receivables from sellers and payables to

sellers.
2. Invoice sellers for accounts receivables.
3. Process FMS accounts payable refund request to sellers (see
Refund Reconciliations for specific requirements).
4. Process overpayment refund collections from Selling lenders.
5. Maintain clear audit trail of overpayment refundtransactions
processed to Treasury deposits.
d) Daily reconciliation to assure that the FMS net funding transactions purchasing
loans equal the net loans accepted and either posted or pending posting
(traceable in work in process files) to the servicing system by the next day.
e) Daily reconciliation of activity sent from sellers to accepted and either posted or
pending posting (traceable in work in process files) on the servicing system.
35. The servicer shall reconcile transfers as follows:
a) Servicer will providefor loan exchange and reconciliationsbetween servicing
system and FSA servicing systems. Servicer will maintain portfolio integrity upon
re-entry into the servicing system.
b) Perform daily reconciliation on transfers of loans between the Servicing system
and each FSA servicing system.
c) Perform monthlyreconciliationof transfersof loans between the servicingsystem

and each FSA servicing system.
36. The servicer shall reconcile cash collections as follows:
NOTE: The terms "recycle file··, "suspense account" and "unapplied file" are
defined as the transactional level cash payments and payment adjustments
received but not posted to borroweraccountson the servicingsystem.
a) Record all incoming check & electronic collections received (deposits) to the
cash clearing account (level 1); reverse collectiontransactionsfrom cash clearing
account when posted to borrower accounts (level 2).
b) The application process for postable cash payments and payment returns must
be completed within 48 hours of collection receipt.
c) Reconcile all cash activity to Treasury daily. This includes, but is not limited to:
electronic funds transfer (EFT), checks (SF 1166), Intra-governmental Payment
and Collection (IPAC) System/SF 1081 payments, internal electronic cash
transactions, and any other payments to or deposits with Treasury.
d) Perform daily collectionreconciliationamong the various Treasury receipt
channels (i.e. Lockbox, Pay.gov, Remittance Express, and IPAC), servicing
system and FMS general ledger. Collection transactions are to be posted to FMS
daily.
e) Daily reconciliation to ensure Total Cash Received (check and electronic) =
(Total Cash Payments Posted to Borrower's accounts+ New Recycle File Items).
f) Daily reconciliation to ensure Outstanding Recycle File Balance = Beginning
Recycle File Balance + New Recycle File Items - Recycle File Items Posted to
Borrower Accts - Refunds of Misdirected Payments - Treasury Escheatment.
g) Monthly reconciliation of the Servicer's unapplied cash payment recycle file
balance at the servicing system to the FMS Unapplied Collections general ledger
account.
h) Monthly reconciliation of Treasury bank statement to FMS and Treasury.
37. The servicer shall reconcile refunds as follows:
a) Maintain daily and monthly three-way reconciliation of refund activity among the
servicing system, FMS accounts payable system and Treasury.
1. Process overpayment refunds, refund cancellations, and stop payments
posted to borrower accounts.
2. Refund transactions processed on the servicing system for misdirected
payments.
3. Track and reconcile refund transactions to refund requests (FMS accounts
payables) to Treasury confirmations.
4. Track and reconcile refund cancellation transactions processed on servicing
to refund reversals in FMS to Treasury cancellations.
38. The servicer shall provide ad hoc reporting tools to support reconciliations:
Servicing Trial Balance by Portfolio - using FSA/FMS transactional account
mapping, must be capable of producing daily, weekly, ad hoc, and monthly trial
balances at a summary and detailed transactional. If multiple databases are
employed each database will be reported individually as well as on a consolidated
basis.
39. The servicer shall perform daily, weekly and monthly system balancing of all data
transmitted to and from the servicing system.
a) Balancing will be done at the transaction type, transaction count and
transaction amount(s) levels.
b) Balancing will ensure data sent= data received; and data received will=
the sum of data accepted and rejected.
c) Rejected data will be researched, resolved/resent by the originating
system.
Additional Reporting
40. The servicer shall provide a data file (daily for the previous day's activity, monthly for
previous month's activity) to FSA containing standard data elements needed for
additional financial and portfolio analysis. FSA will determine the type of file,
transfer specifications, and specific data elements to be included in the file.
41. The Servicer shall ensure that the balances reported to FSA within the daily/monthly
data files reconcileto the balances reported in the Servicer'sservicingsystem as
well as to the Servicer"s FMS accounting interface file.
42. The servicer shall provide reasonable additional support as needed (e.g., data files,
reports, source documents) to substantiate reported activity and balances.
Security
43. The Servicer shall restrict access to FSA held loans being serviced from all other
loans on their system. Access must be limited to personnel who have obtained
proper clearances and who are specificallyauthorizedto view or perform
transactions and services on loans held by FSA.
44. The servicer shall provide previous security information from the past three years to
include a discussion of security incidents; and audits like SAS ?Os, Sarbanes Oxley
reviews, independentsecurityassessments,risk assessments,and/or internal
reviews along with the applicable remediation plans.
45. The servicer shall provide its system's most current vulnerability scan results, and
remediationplan.
46. The servicer shall provide existingsecuritydocumentationlike its security
organizational structure, its system's boundary, existing security policy, procedures,
and plans.
47. The servicer shall complete personnel background screening requirements ASAP.
a) All personnel are required to complete a federal background clearance based on
their position risk level. Background clearances are submitted on line via Office of
Personnel Management (OPM)'s Electronic Questionnaire for Investigations
Process (e-Oip). Contractor employees who have undergone appropriate
personnelsecurityscreeningfor anotherfederal agency may submit proofof
personal security screening for validation. (Attached Security Attachment A -
Department of Education's Directive for Contractor Employee Personnel Security
Screenings.)
b) Preliminary clearances must be completed for high-risk positions prior to working
on Federal Student Aid systems or data (This process can take 2-6 weeks).
Moderate and low risk positionsmust submit backgroundclearance paperwork

priorto workingon Federal Student Aid computer resources.
c) Non-U.S. Citizen may be assigned to a High Risk IT (6C) level position, provided:
he/she is a Lawful Permanent Resident of the United States and has resided
continuously in the United States for a minimum of three (3) years. Non-U.S.
Citizens living outside of the United States cannot have the capability to access
Federal Student Aid systems or data.
48. The servicer shall complete a self-assessment of it's system and facilities based on
NIST SP 800-53 controls, identify security deficiencies/gaps, and create a
remediationplan for the identifieddeficiencies.
49. The servicer shall agree to provide support for all actions required for a formal
security authorization and continuous monitoring program as defined by NIST SP
800-37.
50. The servicer shall create a project plan that they will follow to develop a NIST SP
800-18 compliant System Security Plan created in the Department of Education
format.
51. The servicer shall bundle the requested information in requirements 39 - 45 above
as attachmentsto a discussiondocumentthat providesa discussionfor each
requirement and artifact submitted. The cover page for this package will include a
self-certification document identifying the system's security posture to include its
overall securityrisk. The cover page will be signed by the servicer'ssenior security
official and program manager attesting that the information within the package is
accurate.
NSLDS
52. The servicer shall report in the same format as a Guaranty Agency (GA) for all
loans serviced for Federal Student Aid by creating an NSLDS data base extract file
containing FFEL loans and transmit the FFEL Loans data to NSLDS using the
reporting requirements detailed in the GA Data Provider Instructions with minimal
differences. The Servicers will be provided a GA and Lender Code to be associated
with each loan. The Servicers will report the date of default and loan status for
default as day 271, using NSLDS loans status fields. The Cohort Default Rate date
will be reported at day 361, using the NSLDS Claim Payment fields. A list of these
filed changes will be provided. The GA Data Provider Index of fields that are
required of the FFEL servicers in addition to more information on Guaranty Agency
Data Provider Instructions can be found at the GA DPI Link
(http://ifap.ed.gov/nsldsmaterials/0605DPlnstNSLDS.html).
53. The servicer shall use the NSLDS provided DataPrep software (or equivalent) to
perform Extract Validation and create a Submittal file.
54. The servicer shall send the submittal file to NSLDS on an established weekly
schedule.
55. Once loans have been reported, the servicer shall report to NSLDS all FFEL open
loans. Closed loans must be continually reported until closed status is successfully
accepted by NSLDS. This includes loans that are closed prior to initial NSLDS
reporting.
56. The servicer shall retrieve the Load Process Error file from NSLDS for each
submittal.The servicer must review errors and correct as many as possiblebefore
the next weekly submittal.
57. The servicer shall identify when key borrower indicators have change and report on
both the old data and the new data.
58. The servicer shall work with other data providers-including other GAs, the Direct
Loan Program, the Debt Management Collection System, Perkins schools, and the
Common Origination Disbursement System-to resolve identifier conflicts including
assigning pseudo SSNs where appropriate (see NSLDS DPI).
59. The servicer shall update date, amount and reason for defaults based on current
default criteria if the loans are transferred to DMCS or CDDTS. Once a loan has
transferred to DMCS or CDDTS, stop reporting on the loan unless it is transferred
back. When transferringloans the borrowerand loan identifiersmust be the same
identifiers reported to NSLDS. For Rehabilitated Loans, the Date or Maturity should
not change.
60. The servicer shall report as a GA for all loans serviced for Federal Student Aid.
61. The servicer shall utilize NSLDS on-line updating functionality to resolve customer
service issues and to report loan discharge and Teacher Loan Forgiveness
information.
62. The Servicer shall transmit data to and from NSLDS via the Student Aid Internet
Gateway (SAIG) or other approved secure transmission methods. Additional
informationon SAIG transmissionscan be found at
https://www.fsadownload.ed.gov/mainframeguide.htm.
63. The servicer shall meet NSLDS reporting requirements and quality standards. All
data submitted to NSLDS must be as complete and correct as possible.
64. The servicer shall accept and store enrollment data and updates from NSLDS as the
official source of such data.
65. The servicer shall continue to follow Common Manual Delinquency reporting to
schools.
66. The servicer shall provide additional data elements to the re-engineered NSLDS.
These elements will include, but not be limited to: delinquency data, discharge data,
forgiveness data, and school/lSIR data. This data has been worked through the
community on the FFEL Data Standards Team and can be found online.
67. The servicer shall work with FSA data providers on changes to interfaces as re-
engineeringprojectsoccur.
68. The servicer shall accept a file from NSLDS when receiving loans from DMCS and
CDDTS in order to update the records with missing data elements.
Unique Client/Lender Requirements for Federally Serviced Portfolio

69. The servicer shall use the client name Department of Education for this portfolio.
70. The servicer shall use the Government assigned client LID for this portfolio.
71. The servicer shall use the Government assigned Guarantor Code for this portfolio.
72. Each servicer will be assigned a unique code.
73. The servicer shall maintain unique standard reportingfor loans within each Program
(i.e. 08/09 Loan Purchase Program, Puts from 08/09 Participation Program, 09/10
Loan Purchase program, Conduit, Direct Loan, etc.)
74. The servicer shall process refunds via Treasury checks. Refunds are required for
overpayments greater than or equal to $5.00.
75. The servicer shall perform small balance processing as follows:
a) Overpaid Amount - Small balance write-ups of overpaid balances less
than $5.00.
b) Underpaid Amount - Small balance write-off of underpaid balances less
than $25.00.
76. The servicer shall have the ability to charge late charges, but no assessment of late
charges on loans in the ED portfolio is to be assessed at this time.
77. The servicer shall have the ability to charge other fees (i.e. NSF), but no charges for
other fees on loans in the ED portfolio are to be assessed at this time.
78. The servicer shall have the ability to support borrower benefit plans required by each
loan purchase (PUT) program.
79. 799/LARS reporting is not required for ED portfolio.
80. The servicer shall have the ability to perform collection and due diligence activities
"as required by legislation and/or regulations." Servicers will be required to provide
collection and default aversion activity on loans serviced under this contract as long
as the loan remainson the servicer'ssystem. If a borrowerreaches the 360 days
delinquent, the servicer will be required to transfer the loan to the DMCS.
a) The servicer shall send and electronic transfer file to DMCS with required
information about the defaulted borrower and the defaulted loan.
b) The servicer shall provide access to all required collateral information for the
defaulted loan.
c) The servicer shall accept and resolve rejected records received from DMCS.
81. The servicer shall process discharge transactions with required supporting
documentationfollowingthe required regulatoryguidelines.The servicer is required
to facilitate the timely and accurate processing of discharge requests by ensuring
that complete loan discharge documentation for the individual is submitted. The
servicer is also requiredto make a determinationbased on complete loan discharge
documentation and applicable guidelines. Depending on the discharge type, the
Department reviews discharge decisions through a sampling methodology or
conductsa complete review.
82. The servicer shall transfer loans to the Conditional Disability and Discharge System
once loans have been determined as eligible to be transferred.
83. The servicer shall obtain school information needed from the Postsecondary
Education Participants System (PEPS).
84. The servicer shall be prepared to provide procedure and/or training materials when
requested by ED. ED may review these documents to ensure regulatory and
legislative requirements are met.
85. The servicer shall be required to transfer loans to, or accept loans from, another
servicer at the request of ED.
86. The servicer shall provide access to account level information and collateral for all
federally held loans using technology supported by ED (web-based, terminal
emulation, etc.).
Loan Conversion
The loan conversion process occurs when a seller requests ED to purchase loans, and
ED validates the seller's approval to participate, checks the eligibility of the loans,
provides payment to the seller, and takes ownership of the loans as federally held
assets.
Below are the requirementsa servicer must complete in additionto the existing
requirementsto service an FFEL loan:
87. The servicer shall create and maintain a Loan Purchases Tracking Log - to include:
Checklistof loan purchase activities,status of activities,and loan counts/amounts.
SEE Conversion ATTACHMENT A- Sample of Loan Purchases Tracking Log.
88. The servicer shall provide Loan Purchases Tracking Log to FSA, CFO, and OCFO
on a periodicbasis.
89. The servicer shall accept 45-day notices submitted by sellers via email. SEE
Conversion ATTACHMENT B - Sample of 45 Day Notice.
90. The servicer shall inform FSA when a 45-day notice has been received.
91. The servicer shall send an acknowledgement of receipt of the 45 Day notice to the
Seller via email.
92. The servicer shall validate, with FSA contact, the status of the seller's Master Loan
Sales Agreement (MLSA).
93. The servicer shall notify seller if any additional MSLA approvals or documentation
are needed for the sale and schedule the sale date with the seller's Servicer.
94. The servicer shall notify FSA of the status of the MLSA package, if necessary.
95. The servicer shall perform testing of the loan conversion transfer file process with
sellers. SEE Conversion ATTACHMENT C - Sample of a loan conversion transfer
file layout.
96. The servicer shall receive loan conversiontransfer file from the seller via FTP or
other approved transfer method.
97. The servicer shall review the loan conversion transfer file and notify FSA, CFO,
OCFO of differences between the 45-day notice and loan conversion file as needed.
98. The servicer shall perform edits on the loan conversion transfer file. Note: edits may
vary based on purchase program.
99. The servicer shall prepare report identifying any errors with the loan conversion file
and/or any loans not eligible for sale.
100. The servicer shall provide results of edit errors to the seller, FSA, and designated
parties. The servicer shall work with the seller to resolve errors.
101. The servicer shall send an acknowledgement of receipt of the 45 Day notice to
the Seller via email."
102. The servicer shall work with the Seller to confirm sales parameters, including but
not limited to:
a) Identify any loans in the sale have any liens on them.
b) Identify if the loans are part of a Put from Participation or a straight Put to
the Department.
c) Identify timing for receipt of Loan Conversion Transfer file from the
Servicer, if needed.
103. The servicer shall calculate pre-sale totals and final purchase price after errors
have been resolved.
104. The servicer shall create a pre-sale detail loan report including loan details for all
loans included in the sale. SEE Conversion ATTACHMENT D - Sample of pre-sale
detail loan report.
105. The servicer shall transmit pre-sale detail loan schedule to seller for validation by
seller.
106. The servicer shall create invoice total file and submit to SAIG mailbox to be 'swept'
by FSA CFO. SEE ATTACHMENT Conversion E - Invoice total file layout.
107. The servicer shall receive Bill of Sale and related documents. SEE Master Loan
Sale Agreement - Exhibit B - Sample of Bill of Sale.
108. The servicer shall validate Bill of Sale package is authorized and complete.
109. The servicer shall validate Schedule and Security Release Certificate (SRC) has
been received if loans are subject to a security lien. SEE Master Loan Sale
Agreement - Exhibit E - Sample of Schedule and SRC.
110. The servicer shall flag loans subject to a security lien in Tracking Log.
111. The servicer shall accept Notice of Assignments from seller and notify FSA that
payment will be sent to designee if a Notice of Assignment is received. SEE
Conversion ATTACHMENT F-Sample of Notice of Assignment.
112. The servicer shall compare FSA Servicer pre-sale totals to seller's pre-sale
detailed listing of loans sold - identify and resolve differences.
113. The servicer shall request seller to provide updated Bill of Sale documents as
needed.
114. The servicer shall validate FSA approves/disapproves invoice of payment.
115. The servicershall processthe loan sale transactionon servicingsystem when
notified payment has been made. Loans now reside on FSA Servicer's system.
116. The servicer shall reconcile the Servicing System balance and activity to FMS for
each purchasedeal. Resolve and differencesand providethe reconciliationto
FSA.
117. The servicer shall reconcile the Servicing System balance and activity to FMS on a
monthly basis. Resolve and differences and provide the reconciliation to FSA.
118. The servicer shall receive collateraldocumentationand review for completeness.
119. The servicer shall identify and notify seller of missing collateral documentation,
work with seller to obtain required documentation.
120. The servicer shall notify FSA of receipt of collateral and completeness of
documentation.
121. The servicer shall provide storage for, and access to, collateral documentation.
122. The servicer shall accept, edit and process loan adjustment files from Servicer
after close of sale.
123. The Servicer shall coordinate with the Seller to receive and process any sales
transitionand post sale transactions,includingbut not limitedto, borrower
payments, loan cancellations,school refunds, NSF transactionsfor loans

purchased by the Department.
124. The Servicer shall provide a process to Put any ineligible loans back to the Seller,
as needed (process "Unput" transactions).
INTERMEDIATE
All_lntermediateReq_v6.0
All_IntermediateReq_ v6. 0
Additional Servicer - Intermediate Requirements

TABLE OF CONTENTS
General Statement ........................................................................................... 3

Financial Reporting .......................................................................................... 4
Treasury .............................................................................................................
4
Transaction Management .............................................................................. 5
Internal Controls ...............................................................................................
5
Accounting .........................................................................................................
5
Reconc1l1at1ons ..................................................................................................
5
Additional Reporting ........................................................................................ 5
Security ...............................................................................................................
6
NSLDS ..............................................................................................................
10
Additional Requirements for Federally Held Portfolio ............................1o
Loan Conversion ............................................................................................ 11
Records Management ................................................................................... 11
All_IntermediateReq_ v6. 0 2
General Statement
It is the intent of the Department to procure a performance based contract(s)

that promotescompetitionand providesbest of businessservices. To achieve
this goal, the Department expects each servicer to provide commercially
available services that will yield high performing portfolios and high levels of
customer satisfaction. The following statements apply:
Servicers will be required to meet all statutory and legislative

requirements.
Servicerswill use their own discretionin decidingto provideservices or
business functionality that is recommended but not required.
Servicers may leverage all borrower repayment channels while
maintaining existing branding provided all federally held loans are
clearly distinguished and identified.
Small differencesdue to roundingin various calculationsare
understood and accepted providing the calculation itself is in
compliance with federal regulation.
The department will allocate volume based on defined and understood
performancemetrics.
The Department does not intend to provide additional service level
requirements. The Department does, however, expect best of
business practices to be deployed.
The Department will not require the use of the Department or FSA logo
on letters, web sites, etc.
Servicers will have full discretion to promote or not promote services
as long as they meet legislative and regulatory requirements and are
cost neutralto the government.
Services may use their own authentication process as long as the
process is fully compliant with federal IT security guidelines.
With regard to split borrowers, it is acceptable for servicers to handle
requests, phone calls, etc. for all loans being serviced, regardless of
the holder as long as all federal laws and regulations are met.
Financial Reporting
The following Financial Reporting Requirements are required to be implemented

by September 30, 2009:
1. The servicer shall produce the Treasury Report on Receivables (TROR),

for each portfolio, on a monthly basis. The report must meet all
Treasury/FMS guidance (See Treasury attachments A & B). The TROR
must also:
a. Be provided in Microsoft Excel Format:
b. Be provided for the previous month by the 8th business day of the
currentmonth;
c. Include all supporting data/ documentation. The supporting
documentation must also be provided for the previous month (e.g.,
aging information,status information,etc.) in MicrosoftExcel
format, by the 8th business day of the current month.
2. The servicer shall provide all remaining required accounting reports.
a. Consolidating Trial Balance (All Funds)
b. Monthly & Annual Sub ledger Reports (to include Closing reports)
c. Accounting Distribution Reports
d. Specific Collection Reports (e.g. Lockbox, ACH Credits, ACH
Debits, Web payments, Credit Cards, etc.)
e. Receivable Aging Reports (by Fund, Cohort Year, Loan Program
Type, Risk Category)
f. Loan Portfolio Analysis
g. SF-224 for cash transactions with Treasury ED Form
h. Trial balance reports indicatedunder Reconciliation
i. Loan portfolio pertormance reports (by Fund, Loan Type, cohort
year, & Risk Category)
J. Others as determined
Treasury
In 2010, Treasury will implement the Transaction Reporting System (TRS). TRS
will be a centralized repository of detailed collection transaction information. TRS
will provide integratedtransactionand deposit reportingof revenue activity
across all collection systems. Therefore, the servicer will be required to migrate
its data recipient interfaces for the Lockbox (checks and ACH credits), Pay.gov
(ACH debits and credit card payments), and CA$HLINKII (which reports detail for
ACH credits that are not processed via the lockbox servicer, and reports
summary for all deposits from all sources) to TRS. This requirement is estimated
to be effective by September 30, 2010. Treasury's web site contains further
information on the TRS project at http://www.fms.treas.gov/trs/index.html.
Transaction Management
NO Additional Requirements beyond the Initial Requirements
Internal Controls
3. Effective from the first government fiscal year of operations (i.e., as of
9/30/2009), the servicer shall develop and execute the following reports in
response to financial statement audit "Prepared-by-Client" (PBC) data
requests or as requested by management to support other audits or
reviews:
a. Collections Download
b. Write-Offs activity - Download Requirements & Documentation
Requirements
c. Download of Transfers activity to DCMS
d. Additional work products to support responses to auditor inquiries
and requests
.. Refer to the FMS_Attachment_D document attached for additional

details on these requirements.
4. The Servicer shall provide support to FSA in compliance with 0MB

Circular A-123, Appendix C, which incorporates the Improper Payments
Information Act of 2002 (IPIA).
Accounting
Reconciliations
5. The servicer must demonstrate that all data transfers (e.g., interfaces,
files) are balanced across systems and reconciled at the transaction and
balance level and all exceptions noted are aged and resolved timely. The
servicer shall report aging of reconciling items on all reconciliations. The
servicer shall resolve errors and/or variances timely, generally within one
month.
Additional Reporting
6. The Servicer shall provide a Disbursement Date Change (Cohort Year)

Report (required to be implemented by September 30, 2009) - The report
displays all disbursement date changes after each quarter end that
crossed cohort years. It displays the Account Number, Loan Identification
Number, Principal Balances Outstanding, Interest Receivable Balances,
Principal Paid, and Interest Paid.
7. The servicer shall support the FSA implementation of a 'Data Warehouse'
including the conversion of the daily/monthly file transfers to the
warehouse. FSA will determine the type of file, transfer specifications,
and specific data elements to be included in the file.
Security
Federal Student Aid agrees with the Office of Management and Budget (0MB)
and Congress that the security of its data and IT resources is one of our highest
priorities. Recognizing the need for agencies to have effective information
security programs, Congress passed the Federal Information Security
Management Act (FISMA) of 2002. FISMA provides the overall framework for
ensuring the effectiveness of information security controls that support federal
computer operations and assets. FISMA requirements apply to all federal
contractors and organizations or sources that possess or use federal
information or that operate, use, or have access to federal information
systems on behalf of an agency. FISMA mandates the use of the standards
created by the National Institute of Standards and Technology (NIST). and
Federal Student Aid has adopted those standards and guidance for securing its
information technology resources.
Federal Student Aid security requirements indicated below ensure the confidentiality.
integrity and availability of its data at a high level. System controls need to be tested and
system documentation reviewed using an independent source. If adequate security is in
place, Federal Student Aid will provide a formal security authorization to operate (ATO).
Additional detailed requirements can be found in NIST security standards. special
publications, and bulletins; 0MB memorandums; and the Department of Education
(DoED) policies and procedures. The primary document Federal Student Aid uses to
identify and implement controls is NIST SP 800-53. The latest version of this guidance
can be found at: http://csrc.nist.gov/publications/nistpubs/800-53-Rev2/sp800-53-rev2-
final.pdf
Personnel
8. All personnel are required to complete a federal background clearance
based on their position risk level. Background clearances are submitted
on line via Office of Personnel Management (OPM)'s Electronic
Questionnaire for Investigations Process (e-Oip). Contractor employees
who have undergone appropriate personnel security screening for another
federal agency may submit proof of personal securityscreeningfor

validation. (Attached:Department of Education'sDirectivefor Contractor
Employee Personnel Security Screenings)
9. Preliminary clearances must be completed for high-risk positions prior to
working on Federal Student Aid systems or data (This process can take 2-
6 weeks). Moderate and low risk positions must submit background
clearance paperwork prior to working on Federal Student Aid computer
resources.
10. Non-U.S. Citizen may be assigned to a High Risk IT (6C) level position,
provided: he/she is a Lawful Permanent Resident of the United States and
has resided continuously in the United States for a minimum of three (3)
years. Non-U.S. Citizens living outside of the United States cannot have
the capability to access Federal Student Aid systems or data.
11.AII personnel are required to successfully complete initial security
awareness training within two weeks of employment and annual refresher
training. The training can be completed on line using DoED's security
trainingprogram.
12.Annual specialized training is required that is appropriate to job function.
Facility
13. Data Centers supporting Federal Student Aid systems are required to
have controlledaccess with workingsecuritycameras..
14. Data center access control lists must be kept current. .
15. Visitors must be logged and escorted at all times.
16. Power equipment and power cabling for the information system must be
protected from damage and destruction. Facility failover power and
lighting are required for emergencies.
17. The facility must employ and maintain fire suppression and detection,
water damage controls, and temperature and humidity controls.
18.Alternate data center worksites are required to have the same protections
as the primary data center site.
Telecommunications
19. Data transfers of PII or other sensitive information must be encrypted
using NIST certified encryption methods (see NIST standard, FIPS 140-2)
20.AII interconnectionsmust be documentedand have an Interconnection
Security Agreement in place. (see NIST SP 800-47)
21. Wireless communication containing Federal Student Aid information is not
permitted within the data center.
22. The Federal Student Aid System Security Officer must approve all remote
access.
Contingency Planning and Recovery

23.A contingency/ disaster recoveryplan is requiredto providecontinued
operationalservice within 72 hours of a major catastrophe.
24. Contingency plans must be tested at a recovery site annually using both
DoED and Contractor personnel.
25. The recovery site(s) must be geographically separated from the
production site(s).
26. Data sanitation at the recovery site is required after testing. (see NIST SP
800-88)
27. System backups must be encrypted and kept at an alternate location with
secured access. Sensitive backup tapes must be marked and have a
secure transfer. (Attached: Federal Student Aid"s General Support
System and Major Application Backup Media Handling Policy &
Procedures)
Risk Management
28.Annual self-assessmentof securitycontrolsis required.
29. Independent risk assessments will be completed prior to system's
operation and then reassessed at a minimumof every three years.
30. Independent security controls assessment will be completed.
31.AII identified vulnerabilities and security weaknesses will be captured and
corrective actions tracked through Federal Student Aids Operational
Vulnerability Management Solution (OVMS). Security remediations must
be implementedto correctsecuritydeficienciesand appropriateevidence
must be provided to close actions.
32. Contractors will make themselves and the site available for security audits
and control assessments. This includes interviews with key security staff,
data gathering and submissions,scanningsupport,and escort activities.
33. Federal Student Aid will have the right to test controls through
independent scanning within the boundaries of the Federal Student Aid
system and by other means like interviews,observations,and to
document reviews.
Security Documentation
34. The contactor will develop, implement, and maintain a current system
security plan (SSP) for the information system to provide an overview of
the security requirements for the system and a description of the security
controls in place or planned for meeting those requirements. Designated
officials within Federal Student Aid will review and approve the plan. (see
NIST SP 800-18)
35.A contingency plan must be created, approved, and tested annually.
36.A configuration management plan must be created, approved, and
implemented.
37. Documented system boundaries are required. A documented inventory of
hardwareand softwareutilized,telecommunication interconnectionsand a
network topology are required. (Attached: Federal Student Aid's
Boundary Definition template).
38. System access authorizations and signed rules of behavior must be
maintained.
39. Plans of Actions and Milestones that address security remediations are
maintained in Federal Student Aid"s Operational Vulnerability
Management Solution.
Security Monitoring and Detection

40. Network intrusion detection systems (NIDS) and host-based intrusion
detection systems (HIDS) are configured appropriately and continuously
monitored and updated if necessary.
41. Systems will have appropriate auditing capabilities enabled.
42. System logs are to be analyzed for suspicious activity. Logs will be made
available to Federal Student Aid upon request.
43. Compliance monitoring established for configuration settings.
44. Routine network and database scans are scheduled. The scan results are
analyzed and vulnerabilities identified. The identified vulnerabilities and
actions taken will be documented in OVMS.
45. Scans that identify web vulnerabilities will be completed. Scan results will
be provided to FSA upon request. The identified vulnerabilities and actions
taken will be documented in OVMS.
46. Security remediations must be implemented to correct security
deficiencies and appropriate evidence must be provided to close actions.
Incident Response
47.Contractor must maintain an incident response plan that correlates to the
DoED plan.
48. Compromises of personal identifiable information (PII) must be reported
immediately so that the Department can comply with its reporting
requirements to report to U.S. Computer Emergency Readiness Team
(CERT) within one hour of the incident.
49. Contractormust preserve evidence and allow externalforensicanalysis
either on-site or through shipment of components.
50. Contractor must take appropriate actions for alerts and warnings provided
by DoED or through other sources. Contractor will report status of their
actionsas requested.
Security Configurations
51. Federal Student Aid data must be segregated from non-Federal Student
Aid data.
52. Security patches must be kept current and appropriately tested prior to
moving into production.
53. Server and device securityconfigurationsmust be maintainedin
accordance with NIST security configuration standards (See:
http ://checklists. nist.gov/).
54. Passwords must meet Federal Student Aid's password standards.
(Attached: Federal Student Aid's Password Parameters Policy &
Procedures)
55. Change control management procedures must be documented and

followed.
56. Federal Student Aid must approve system changes prior to production
implementation.
57. Data will be safeguarded commensurate with the highest categorization
level based on FIPS 199.
Access Control
58. Federal Student Aid must approve all access to Federal Student Aid data
and all contractor access that can affect any component within the
system's boundary.
59.Application access reports need to be sent quarterly to Federal Student
Aid for certificationof access.
60.A listing of IT personnel responsible for operations and maintenance of
any Federal Student Aid system must be provided on a quarterly basis to
FSA for certification of access.
61.Access must be restricted based on least privilege. Role based access
controls should be defined and documented.
NSLDS
62. The Servicer shall provide the National Student Loan Clearinghouse
monthly updates to their federally serviced portfolio. National Student
Clearinghouse (NCS) will provide weekly updates to NSLDS for all FFEL
and DL loans in the FSA portfolio. NSLDS will provide the servicer with
weekly enrollment data that include NSC updates.
Additional Requirements for Federally Held Portfolio
63. The servicer shall receive collateral in imaged and paper format and if
received in paper format image it should be imaged in a format that can be
ported easily to another system (Non-proprietary)
64. The servicer shall verify collateral for all loans received in a sale within 45
days and if any collateral is missing the missing collateral will be obtained
from the seller.
65. The servicer shall provide for FSA access to the imaging and serving
systemto view images, make annotationson borroweraccountsand have
complete access to view FSA data.
66. The servicer shall provide a means for FSA to make a final determination
on eligibility of borrowers for entitlements, such as discharge due to
Closed School, Death, etc., and compromise offers.
67. The servicer shall report loans to NSLDS and credit bureaus.
68. The servicer shall cancel loans and make all financial adjustments when
needed.
69. The servicer shall place loans, where the borrower has applied for
bankruptcy, into a bankruptcy status, prepare a Proof-of-Claim and
provide any additional support needed to defend the loan against

bankruptcy discharge.
70. The servicer shall accurately prepare and respond to control
correspondence (correspondence sent to FSA from the White House,
Congress, and other high government officials) and meet control
turnaround times established by the U.S. Department for FSA.
71. The servicer shall respond to written and email questions and requests
timely and accurately.
72. The servicer shall respond and resolve customercomplaints;and create
and execute a plan to escalate complaints to FSA and the Ombudsman.
73. The servicer shall have the ability to provide borrower interest rate
discounts and assess late fees if directed to do so by FSA.
74. The servicer shall accurately and timely complete and return Loan
VerificationCertificatesreceived from consolidatinglenders.
75. The servicer shall assign loans to DMCS for collection once they reach
360 days delinquent. If a loan is assigned in error the loan will be
reinstatedonto the servicer'ssystem.
76. The servicer shall have the ability to accept and service loans that
undergo rehabilitation from the DMCS.
77. The servicer shall provide FSA the ability to monitor phone calls remotely.
78. The servicer shall support quarterly monitoring reviews completed by FSA.
79. The servicer shall supportannual programcompliance reviews done by
FSA, or by an agent of FSA.
Loan Conversion
Records Management
80. The Servicer shall comply with all of the following standard items related
to recordsmanagement:
a. Citations to pertinent laws, codes and regulations such as 44 U.S.C

chapters 21, 29, 31 and 33; Freedom of Information Act (5 U.S.C.
552); Privacy Act (5 U.S.C. 552a); 36 CFR Part 1222 and Part
1228.
b. Contractor shall treat all deliverables under the contract as the

property of the U.S. Government for which the Government Agency
shall have unlimited rights to use, dispose of, or disclose such data
containedtherein as it determinesto be in the publicinterest.
All_IntermediateReq_ v6. 0 II
c. Contractorshall not create or maintainany recordsthat are not

specifically tied to or authorized by the contract using Government
IT equipment and/or Government records.
d. Contractor shall not retain, use, sell, or disseminate copies of any

deliverable that contains information covered by the Privacy Act of
1974 or that which is generally protected by the Freedom of
Information Act.
e. Contractor shall not create or maintain any records containing any

Government Agency records that are not specifically tied to or
authorized by the contract.
f. The Government Agency owns the rights to all data/records

produced as part of this contract.
g. The Government Agency owns the rights to all electronic

information(electronicdata, electronicinformationsystems,
electronic databases, etc.) and all supporting documentation
created as part of this contract. Contractor must deliver sufficient
technical documentation with all data deliverables to permit the
agency to use the data.
h. Contractor agrees to comply with Federal and Agency records

management policies, including those policies associated with the
safeguarding of records covered by the Privacy Act of 1974. These
policiesincludethe preservationof all recordscreated or received
regardless of format [paper, electronic, etc.] or mode of
transmission [e-mail, fax, etc.] or state of completion [draft, final,
etc.].
1. No disposition of documents will be allowed without the prior written

consent of the Contracting Officer. The Agency and its contractors
are responsiblefor preventingthe alienationor unauthorized
destruction of records, including all forms of mutilation. Willful and
unlawful destruction, damage or alienation of Federal records is
subject to the fines and penalties imposed by 18 U.S.C. 2701.
Records may not be removed from the legal custody of the Agency
or destroyed without regard to the provisions of the agency records
schedules.
j. Contractor is required to obtain the Contracting Officer's approval

prior to engaging in any contractual relationship (sub-contractor) in
supportof this contract requiringthe disclosureof information,
documentary material and/or records generated under, or relating
to, this contract. The Contractor (and any sub-contractor) is
required to abide by Government and Agency guidance for

protectingsensitiveand proprietaryinformation.
Additional Information regarding records management:

Extract from 36 CFR Part 12, regarding records management
responsibilities of contractors.
§ 1222.48 Data created or received and maintained for the Government by
contractors.
(a) Contractors pertorming Congressionally mandated program functions are
likely to create or receive data necessary to provide adequate and proper
documentation of these programs and to manage them effectively. Agencies
shall specify the delivery of the Government of all data needed for the adequate
and proper documentationof contractor-operatedprogramsin accordancewith
requirements of the Federal Acquisition Regulation (FAR) and, where applicable,
the Defense Federal Acquisition Regulation Supplement (DFARS).
(b) When contracts involve the creation of data for the Government's use, in
addition to specifying a final product, agency officials may need to specify the
delivery of background data that may have reuse value to the Government.
Before specifying the background data that contractors must deliver to the
agency, program and contracting officials shall consult with agency records and
information managers and historians and, when appropriate, with other
Government agencies to ensure that all agency and Government needs are met,
especiallywhen the data deliverablessupporta new agency missionor a new
Government program.
(c) Deferred ordering and delivery-of-data clauses and rights-in-data clauses
shall be included in contractswhenever necessaryto ensure adequate and
proper documentation or because the data have reuse value to the Government.
(d) When data deliverables include electronic records, the agency shall require
the contractor to deliver sufficient technical documentation to permit the agency
or other Government agencies to use the data.
(e) All data created for Government use and delivered to, or falling under the
legal control of, the Government are Federal records and shall be managed in
accordance with records management legislation as codified at 44 U.S.C.
chapters 21, 29, 31, and 33, the Freedom of Information Act (5 U.S.C. 552), and
the Privacy Act (5 U.S.C. 552a), and shall be scheduled for disposition in
accordance with 36 CFR part 1228.
36 CFR Part 1228, Subpart K - Facility Standards for Records
Storage Facilities.
NARA requires that the requirements of Subpart K be incorporated into the
contract requirementswhen recordsstorage facilitiesare includedin the contract.
This covers direct contractswith commercialstorage vendors such as Iron
Mountain; it also covers contractors who store ED records as part of a larger
service contract. http://www.archives.gov/about/regulations/part-1228/k.html
Full_Req_v6.0
Full_Req_v6.0
Additional Servicer - FULL Requirements

TABLE OF CONTENTS
General Statement ..........................................................................................

3
Direct Loans .....................................................................................................
4
Full_Req_v6.0 2
General Statement
It is the intent of the Department to procure a performance based contract(s)

that promotescompetitionand providesbest of businessservices. To achieve
this goal, the Department expects each servicer to provide commercially
available services that will yield high performing portfolios and high levels of
customer satisfaction. The following statements apply:
Servicers will be required to meet all statutory and legislative

requirements.
Servicerswill use their own discretionin decidingto provideservices or
business functionality that is recommended but not required.
Servicers may leverage all borrower repayment channels while
maintaining existing branding provided all federally held loans are
clearly distinguished and identified.
Small differencesdue to roundingin various calculationsare
understood and accepted providing the calculation itself is in
compliance with federal regulation.
The department will allocate volume based on defined and understood
performancemetrics.
The Department does not intend to provide additional service level
requirements. The Department does, however, expect best of
business practices to be deployed.
The Department will not require the use of the Department or FSA logo
on letters, web sites, etc.
Servicers will have full discretion to promote or not promote services
as long as they meet legislative and regulatory requirements and are
cost neutralto the government.
Services may use their own authentication process as long as the
process is fully compliant with federal IT security guidelines.
With regard to split borrowers, it is acceptable for servicers to handle
requests, phone calls, etc. for all loans being serviced, regardless of
the holder as long as all federal laws and regulations are met.
Full_Req_v6.0 3
Direct Loans
1. The servicer shall meet all legislative and regulatory requirements for the
Direct Loan program (DL). In some cases Direct Loans will need to be
serviced differently than FFEL loans, a few examples of these differences
are listed below (not an all inclusive list):
a. The interest rate for a Federal Direct PLUS loan is fixed at 7.9% for
loans first disbursed after July 1, 2006.
b. Public service loan forgiveness is only offered in the DL.
c. There are two repayment plans unique to the DL: Income
Contingent Repayment (ICR) and the Alternative Repayment.
d. DL providesa 0.25% interestrate reductionfor borrowersmaking
payments through electronic debit accounts.
e. As of July 1, 2009 the up front interest rebate for direct subsidized
and unsubsidized loans will be 1.00%.
f. There is an origination fee but no Federal default fee in the DL. As
of July 1, 2009, the origination fee will be 1.5% for direct subsidized
and direct unsubsidized loans.
g. There is authority in the DL for unlimited discretionary
forbearances. DL servicers must be able to offer borrowers
additional administrative forbearance after the 3-year limit and upon
receipt of additional documentation from the borrowers.
2. The servicer shall meet all previously identified requirements for Federally
Held Debt (i.e. Accounting, Treasury, Reconciliation, Internal Controls,
etc.) for the Direct Loan portfolio.
3. The servicer shall interface with Common Origination and Disbursement
System (COD) & Electronic Master Promissory Note (eMPN) for newly
originatedloans.
4. The servicer shall interface with the Direct Loan Consolidation System
(DLCS) for Direct Consolidation Loans.
5. The servicers shall accept loan and disbursement level adjustments from
the originating system(s) and/or directly from schools as necessary. The
majority of Direct Loan adjustments & cancellations are passed from the
school to COD, and then from COD to the servicing system via the
servicing system/COD interface. Direct Consolidation Loan adjustments &
cancellationsare received by the servicingsystem from the Direct Loan
Consolidation System (DLCS) via the servicing system/DLCS interface
6. The servicer shall interface with Internal Revenue Service (IRS) as
needed to support income contingent or income based programs.
7. The servicer shall support servicing of all Direct Loans, including Direct
ConsolidationLoans.
Full_Req_v6.0 4
Attachment A-4
Ongoing Allocation Methodology
The allocation of ongoing volume will be detennined based on the performance of each servicer in
relation to the other servicers awarded. While the total number of awarded servicers has not yet been
determined. this methodology works with any number of servicers (as shown in examples).
Quarterly scores will be compiled for each servicer based on various performance factors; five high-level
metrics, and some sub-metric categories, have been defined (see below). An average of the quarterly
scores available on July 1 of each year will be used to determine the ranking of each servicer in each of
the five high-level metric categories. By combining each servicer's ranking in all categories, each servicer
will be given a percentage of the total new volume of Federally Held Debt to be distributed for the
upcommg year.
Servicers will be informed of their allocation percentage of new volume by July 15 of each year. This
allocation will become effective on August 15 of each year. The first ongoing allocation will be provided
by August 15, 20!0.
The allocation of ongoing volume will be detennined based on the following factors:
1. Percentage of ''In Repayment" Portfolio Dollars that go into default (as transferred to DMCS -
360+ days) - Measured as a percentage of the servicer's cmTent Federally held portfolio
a. Percentage at Public Schools
b. Percentage at Private Schools
c. Percentage at Proprietary Schools
2. Percentage of unique ''In Repayment" Portfolio borrowers that go into default (as transferred to
DMCS - 360+ days)-Measured as a percentage of the servicer's current Federally held portfolio
b. Percentage at Private Schools
c. Percentage at Proprietary Schools
3. Borrower Surveys
a. In School Borrowers
b. In Grace Borrowers
c. In Repayment Borrowers
4. School Surveys
a. Public Schools
b. Private Schools
c. Proprietary Schools
5. Survey of FSA personnel
Allocation Metric# 1- to be measured Quarterly (calendar quarters beginning with October I. 2009).
Calculation= (Total Principal Balance Outstanding (or "PBO") + Interest of all loans sent to DMCS
during the quarter or> 360 days delinquent at the end of the quarter) DIVIDED BY (Total PBO + Interest
of all of the servicer's Federally held debt portfolio in repayment status). Resulting value is a percentage
rounded to the nearest hundredth for each category of schools (Public. Private, Proprietary). All available
quarterly scores in each category ( 1a, 1b. le) will be averaged together on July I of each year to calculate
the Final Score for this allocation metric.
Allocation Metric# 2 - to be measured Quarterly (calendar quarters beginning with October I. 2009).
Calculation= (Total number of borrowers sent to DMCS during the quarter or> 360 days delinquent at
Pagelof3
Attachment A-4
the end of the quarter) DIVIDED BY (Total number of borrowers within the servicer' s Federally held
debt portfolio in repayment status). Resulting value is a percentage rounded to the nearest hundredth for
each category of schools (Public, Private. Proprietary). All available quarterly scores in each category (2a,
2b, 2c) will be averaged together on July 1 of each year to calculate the Final Score for this allocation
metric.
Allocation Metric # 3 - Surveys will be conducted quarterly of boJTowers in each category (In School. In
Grace, and In Repayment). The survey will measure borrower satisfaction with the servicer and results
will be based on a scale of 0 - 100°/41,
with 100% representing a perfect score. FSA, or an agent of FSA
will conduct surveys. All available quarterly scores in each category (3a. 3b, 3c) will be averaged together
on July 1 of each year to calculate the Final Score for this allocation metric.
Allocation Metric# 4 - Surveys will be conducted quarterly of schools in each category (Public, Private,
and Proprietary). The survey will measure school satisfaction with the servicer and results will be based
on a scale of O- 100%, with 100% representing a perfect score. FSA. or an agent of FSA will conduct
surveys. All available quarterly scores in each category (4a, 4b, 4c) will be averaged together on July 1 of
each year to calculate the Final Score for this allocation metric.
Allocation Metric # 5 - Surveys will be conducted quarterly of FSA personnel. The survey will measure
FSA satisfaction with the servicer and results will be based on a scale of 0 - 100%, with 100%
representing a perfect score. FSA, or an agent of FSA will conduct surveys. All available quarterly scores
will be averaged together on July 1 of each year to calculate the Final Score for this allocation metric.
Allocation Metric Score Comparison Among Servicers

The above calculation will result in a set of 5 scores for each servicer, one score in each metric category
(I-Defaulted borrower dollars, 2-Defaulted borrower count. 3-Borrower Survey. 4-School Survey. 5-FSA
Survey).
FSA will compare all servicers' scores in each allocation metric category and provide a ranking for each
servicer in that category, with the best score in each category receiving the highest possible value and the
worst score receiving the lowest possible value (highest/ lowest values will be determined by the number
of servicers selected --- Highest score possible will be the total number of servicers selected, lowest score
will be I).
Once a ranking value has been assigned to each servicer in each allocation category. all scores for a
servicer will be added together to provide the "Total Score'' for that servicer for the year. Each servicer
will have one Total Score for each year.
Allocation of New Volume of Federally Held Debt

Each servicer will be assigned an allocation of new volume by dividing that servicer's total score by the
combined total scores of all servicers. The resulting percentage will determine each servicer's percentage
of new volume of Federally Held Debt.
The servicer's percentage of new volume will determine the percentage of new borrowers that will be
sent to the servicer for servicing (loans for existing borrowers may, to the maximum extent practicable, be
sent to the servicer already holding that borrower's other loans).
NOTE: If a sen'icer is out r~{compliance ({or example, but not limited to, financial management or
reporting, security, 0MB Circular A-123, Legislative Mandates, Program Compliance, etc.), that
Page 2 of3
Attachment A-4
sen,icer's neiv volume may be re-allocated to one or more other servicers until compliance has been
achieved. In addition, that servicer's current account volume may be transferred to another sen'icer,
at the non-compliant servicer's expense.
Page 3 of3
Attachment A-5
SAMPLE - ONGOING ALLOCATION METRIC CALCULATION

Scenario 1 - 6 Servicers selected
FINAL SCORE BY ALLOCATION METRIC
Servicers
METRIC 1 2 3 4 5 6
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40% 5.50% 6.60%
2 Defaulted borrower amount 1.10% 2.20% 3.30% 4.40% 5.50% 6.60%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00% 90.00% 89.00%
4 School Survev 97.00% 95.00% 93.00% 91.00% 90.00% 89.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00% 90.00% 89.00%
SERVICER RANKING BY ALLOCATION METRIC

Servlcers
METRIC 1 2 3 4 5 6
1 Defaulted borrower count 6.0 5.0 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 6.0 5.0 4.0 3.0 2.0 1.0
3 Borrower Survey 6.0 5.0 4.0 3.0 2.0 1.0
4 School Survev 6.0 5.0 4.0 3.0 2.0 1.0
5 FSA Survev 6.0 5.0 4.0 3.0 2.0 1.0
TOTAL SCORE BY SERVICER Servicers

1 I 2 I 3 I 4 I 5 I 6
I TOTAL SCORE 30.01 25.01 20.01 15.01 10.01 5.0
ALLOCATION EACH SERIVER WILL RECEIVE
% of new volume New

Servicer will receive borrowers
(Total Score/ Combined (based on 6M
Total Score Totals) total new borr)
Servicer 1 30.0 28.57% 1,714,286
Servicer 2 25.0 23.81% 1,428,571
Servicer 3 20.0 19.05% 1,142,857
Servicer 4 15.0 "14.29% 857,143
Servicer 5 10.0 9.52% 571,429
Servicer 6 5.0 4.76% 285,714
Combined
Total 105 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3 4 5
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40% 5.50%
2 Defaulted borrower amount 1.10% 2.20% 3.30% 4.40% 5.50%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00% 90.00%
4 School Survev 97.00% 95.00% 93.00% 91.00% 90.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00% 90.00%

Servlcers
METRIC 1 2 3 4 5
1 Defaulted borrower count 5.0 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 5.0 4.0 3.0 2.0 1 .0
3 Borrower Survey 5.0 4.0 3.0 2.0 1 .0
4 School Survev 5.0 4.0 3.0 2.0 1 .0
5 FSA Survev 5.0 4.0 3.0 2.0 1.0

1 I 2 I 3 I 4 I 5
I TOTAL SCORE 25.01 20.01 15.01 10.01 5.0
ALLOCATIONEACH SERIVER WILL RECEIVE
% of new volume New

Servicer wlll receive borrowers
Servicer 1 25.0 33.33% 2,000,000
Servicer 2 20.0 26.67% 1,600,000
Servicer 3 15.0 20.00% 1,200,000
Servicer 4 10.0 "13.33% 800,000
Servicer 5 5.0 6.67% 400,000
Combined
Totals 75 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3 4
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40%
2 Defaulted borrower amount 1.10% 2.20% 3.30% 4.40%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00%
4 School Survev 97.00% 95.00% 93.00% 91.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00%

Servlcers
METRIC 1 2 3 4
1 Defaulted borrower count 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 4.0 3.0 2.0 1.0
3 Borrower Survey 4.0 3.0 2.0 1.0
4 School Survev 4.0 3.0 2.0 1.0
5 FSA Survev 4.0 3.0 2.0 1.0

1 I 2 I 3 I 4
I TOTAL SCORE 20.01 15.01 10.01 5.0
% of new volume New

Servicer 1 20.0 40.00% 2,400,000
Servicer 2 15.0 30.00% 1,800,000
Servicer 3 10.0 20.00% 1,200,000
Servicer 4 5.0 I 0.00% 600,000
Combined
Totals 50 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3
1 Defaulted borrower count 1.10% 2.20% 3.30%
2 Defaulted borrower amount 1.10% 2.20% 3.30%
3 Borrower Survev 97.00% 95.00% 93.00%
4 School Survev 97.00% 95.00% 93.00%
5 FSA Survey 97.00% 95.00% 93.00%

Servlcers
METRIC 1 2 3
1 Defaulted borrower count 3.0 2.0 1.0
2 Defaulted borrower amount 3.0 2.0 1 .0
3 Borrower Survey 3.0 2.0 1 .0
4 School Survev 3.0 2.0 1 .0
5 FSA Survev 3.0 2.0 1.0

1 I 2 I 3
I TOTAL SCORE 15.01 10.01 5.0
% of new volume New

Servicer 1 15.0 50.00% 3,000,000
Servicer 2 10.0 33.33% 2,000,000
Servicer 3 5.0 16.67% 1,000,000
Combined
Totals 30 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2
1 Defaulted borrower count 1.10% 2.20%
2 Defaulted borrower amount 1.10% 2.20%
3 Borrower Survev 97.00% 95.00%
4 School Survev 97.00% 95.00%
5 FSA Survey 97.00% 95.00%

Servlcers
METRIC 1 2
1 Defaulted borrower count 2.0 1.0
2 Defaulted borrower amount 2.0 1.0
3 Borrower Survey 2.0 1.0
4 School Survev 2.0 1.0
5 FSA Survev 2.0 1.0

1 I 2
I TOTAL SCORE 10.01 5.0
% of new volume
Servicer wlll receive New borrowers
(Total Score/ Combined (based on 6M total
Total Score Totals) new borr)
Servicer 1 10.0 66.67% 4.000,000
Servicer 2 5.0 33.33% 2,000,000
Combined
Totals 15 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3 4 5 6
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40% 5.50% 6.60%
2 Defaulted borrower amount 6.60% 5.50% 3.30% 4.40% 2.20% 1.10%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00% 90.00% 89.00%
4 School Survev 89.00% 90.00% 93.00% 91.00% 95.00% 97.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00% 90.00% 89.00%

Servlcers
METRIC 1 2 3 4 5 6
1 Defaulted borrower count 6.0 5.0 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 1.0 2.0 4.0 3.0 5.0 6.0
3 Borrower Survey 6.0 5.0 4.0 3.0 2.0 1.0
4 School Survev 1.0 2.0 4.0 3.0 5.0 6.0
5 FSA Survev 6.0 5.0 4.0 3.0 2.0 1.0

1 I 2 I 3 I 4 I 5 I 6
I TOTAL SCORE 20.01 19.01 20.01 15.01 16.01 15.0
% of new volume New

Servicer 1 20.0 19.05% 1,142,857
Servicer 2 19.0 18.10% 1,085,714
Servicer 3 20.0 19.05% 1,142,857
Servicer 4 15.0 "14.29% 857,143
Servicer 5 16.0 15.24% 914,286
Servicer 6 15.0 14.29% 857,143
Combined
Total 105 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3 4 5
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40% 5.50%
2 Defaulted borrower amount 6.60% 5.50% 3.30% 4.40% 2.20%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00% 90.00%
4 School Survev 89.00% 90.00% 93.00% 91.00% 95.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00% 90.00%

Servlcers
METRIC 1 2 3 4 5
1 Defaulted borrower count 5.0 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 1.0 2.0 4.0 3.0 5.0
3 Borrower Survey 5.0 4.0 3.0 2.0 1 .0
4 School Survev 1.0 2.0 4.0 3.0 5.0
5 FSA Survev 5.0 4.0 3.0 2.0 1.0

1 I 2 I 3 I 4 I 5
I TOTAL SCORE 17.01 16.01 17.01 12.01 13.0
% of new volume New

Servicer 1 17.0 22.67% 1,360,000
Servicer 2 16.0 21.33% 1,280,000
Servicer 3 17.0 22.67% 1,360,000
Servicer 4 12.0 "16.00% 960,000
Servicer 5 13.0 17.33% 1,040,000
Combined
Total 75 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3 4
1 Defaulted borrower count 1.10% 2.20% 3.30% 4.40%
2 Defaulted borrower amount 6.60% 5.50% 3.30% 4.40%
3 Borrower Survev 97.00% 95.00% 93.00% 91.00%
4 School Survey 89.00% 90.00% 93.00% 91.00%
5 FSA Survey 97.00% 95.00% 93.00% 91.00%

Servlcers
METRIC 1 2 3 4
1 Defaulted borrower count 4.0 3.0 2.0 1.0
2 Defaulted borrower amount 1 .0 2.0 4.0 3.0
3 Borrower Survey 4.0 3.0 2.0 1.0
4 School Survev 1 .0 2.0 4.0 3.0
5 FSA Survev 4.0 3.0 2.0 1.0

1 I 2 I 3 I 4
I TOTAL SCORE 14.01 13.01 14.01 9.0
% of new volume New

Servicer 1 14.0 28.00% 1,680,000
Servicer 2 13.0 26.00% 1,560,000
Servicer 3 14.0 28.00% 1,680,000
Servicer 4 9.0 18.00% 1,080,000
CombinedTotal 50 100.00% 6,000,000
Attachment A-5

Servicers
METRIC 1 2 3
1 Defaulted borrower count 1.10% 2.20% 3.30%
2 Defaulted borrower amount 6.60% 5.50% 3.30%
3 Borrower Survev 97.00% 95.00% 93.00%
4 School Survey 89.00% 90.00% 93.00%
5 FSA Survey 97.00% 95.00% 93.00%

Servlcers
METRIC 1 2 3
1 Defaulted borrower count 3.0 2.0 1.0
2 Defaulted borrower amount 1 .0 2.0 3.0
3 Borrower Survey 3.0 2.0 1 .0
4 School Survev 1 .0 2.0 3.0
5 FSA Survev 3.0 2.0 1.0

1 I 2 I 3
I TOTAL SCORE 11.01 10.01 9.0
% of new volume New

Servicer 1 11.0 36.67% 2,200,000
Servicer 2 10.0 33.33% 2,000,000
Servicer 3 9.0 30.00% 1,800,000
Combined Total 30 100.00"/4 6 000.000
Attachment A-5

Servicers
METRIC 1 2
1 Defaulted borrower count 1.10% 2.20%
2 Defaulted borrower amount 6.60% 5.50%
3 Borrower Survev 97.00% 95.00%
4 School Survey 89.00% 90.00%
5 FSA Survey 97.00% 95.00%

Servlcers
METRIC 1 2
1 Defaulted borrower count 2.0 1.0
2 Defaulted borrower amount 1 .0 2.0
3 Borrower Survey 2.0 1.0
4 School Survev 1 .0 2.0
5 FSA Survev 2.0 1.0

1 I 2
I TOTAL SCORE 8.01 7.0
% of new volume New

Servicer 1 8.0 53.33% 3,200,000
Servicer 2 7.0 46.67% 2,800,000
CombinedTotal 15 100.00% 6,000,000
FederalStudentAid AttachmentA-6--ServicingPricingDefinitions
U.S.Departmentof Education Title IV StudentLoanServicing/Management
Deliverable Definition
Borrowers in In-school Status Number of unique borrowers (SSNs) with balance not
equal to $0.00 who have not separated from school
as of the last day of the billing period
Borrowers in Grace or Current Number of unique borrowers (SSNs) with balance not
Repayment Status equal to $0.00 who have separated from school and
are less than 31 days delinquent and are not in
deferment, forbearance, or conditionally discharged
as of the last day of the billing period
Borrowers in Deferment or Number of unique borrowers (SSNs) with balance not
Forbearance equal to $0.00 who have separated from school, are
in deferment or forbearance and who are not
conditionally discharged as of the last day of the
billing period
Borrowers 31-90 Days Number of unique borrowers (SSNs) with balance not
Delinquent equal to $0.00 who have separated from school, are
31 or more days, but less than 91 days delinquent,
and who are not conditionally discharged as of the
last day of the billing period
Delinquent equal to $0.00 who have separated from school, are
Delinquent equal to $0.00 who have separated from school are
Borrowers 270+ Days Number of unique borrowers (SSNs) with balance not
Delinquent equal to $0.00 who have separated from school and
271 or more days and who are not conditionally
discharged as of the last day of the billing period.
This may include borrowers over 360 day that are
considered in Default Status, but for some reason
have not been transferred through no fault of the
Servicer.
NOTES:
1. Common pricing shall apply regardless of program (i.e. Direct Loan, Federal Family
Education Loan) or volume serviced, unless otherwise noted in the contract.
2. Reporting is required for the number of borrowers and/or loans and dollar amount of each
program, in addition to any other reporting requirements provided in the contract.
3. Borrowers in multiple statuses shall be billed once, in the lowest performing deliverable
status. The lowest performing deliverable status is defined as the lowest unit priced
deliverable.
4. Borrowers pending discharge, which include, but are not limited to: conditional disability,
death, or bankruptcy, shall be, for billing purposes, counted in the deliverable status at
the time of the discharge request.
5. 'The last day of the billing period" is defined as the last day of the Department of
Education's monthly billing period.
6. The annual pricing period shall begin on September 1, 2009.
Version9.0 Page1 of 1
USE AND NON-DISCLOSURE AGREEMENT
The undersigned, James L. Preston, an authorized representative of the Pennsylvania

Higher Education Assistance Agency, (which is hereinafter referred to as the "Recipient")
requests the Government to provide the Recipient with proprietary data, technical data or
computer software (hereinafter refeJTed to as "Data") in which the Government's use,
modification, reproduction, release, performance, display or disclosure rights arc restricted.
Those Data are identified in an attachment to this Agreement. In consideration for receiving such
Data, the Recipient agrees to use the Data strictly in accordance with this Agreement:
(I) The Recipient shall -·
(a) Use, modify, reproduce, release, perform, display, or disclose Data marked with
SHIR data rights legends only for government purposes and shall not do so for
any commercial purpose. The Recipient shall not release, perform, display, or
disclose these Data, without the express written permission of the contractor
\.Vhosename appears in the restrictive legend (the "Contractor"), to any person
other than its subcontractors or suppliers, or prospective subcontractors or
suppliers, who require these Data to submit offers for, or perform, contracts with
the Recipient. The Recipient shall require its subcontractors or suppliers, or
prospective subcontractors or suppliers, to sign a use and non-disclosure
agreement prior to disclosing or releasing these Data to such persons. Such
agreement must be consistent with the terms of this agreement.
(b) Use, modify, reproduce, release, perform, display, or disclose proprietary data or
technical data marked with limited rights legends only as specified in the
attachment to this Agreement. Release, performance, display, or disclosure to
other persons is not authorized unless specified in the attachment to this
Agreement or expressly permitted in writing by the Contractor.
(c) Use computer software marked with restricted rights legends only in performance
of Contract Number EDOFSA-09-D-0014. The Recipient shall not, for example,
enhance, decompile, disassemble, or reverse engineer the software; time share, or
use a computer program with more than one computer at a time. The recipient
may not release, perform, display, or disclose such software to others unless
expressly permitted in writing by the licensor whose name appears in the
restrictive legend.
(d) Use, modify, reproduce, release, perform, display, or disclose Data marked with
special license rights legends (To be completed by the contracting officer. See
(a)(2) of the Use and Non-Disclosure Agreement clause. Omit if none of the Data
requested is marked with special license rights legends).
(2) The Recipient agrees to adopt or establish operating procedures and physical security
measures designed to protect these Data from inadvertent release or disclosure to
unauthorized third parties.
(3) The Recipient agrees to accept these Data "as is" without any Government representation
as to suitability for intended use or warranty whatsoever. This disclaimer docs not affect
any obligation the Government may have regarding Data specified in a contract for the
performance of that contract.
(4) The Recipient may enter into any agreement directly with the Contractor with respect to
the use, modification, reproduction, release, performance, display, or disclosure of these
Data.
(5) The Recipient agrees to indemnify and hold harmless the Government, its agents, and
expenses arising out of: or in any way related to, the misuse or unauthorized
modification, reproduction, release, performance, display, or disclosure of Data received
from the Government with restrictive legends by the Recipient or any person to whom the
Recipient has released or disclosed the Data.
(6) The Recipient is executing this Agreement for the benefit of the Contractor. The
Contractor is a third party beneficiary of this Agreement who, in addition to any other
rights it may have, is intended to have the rights of direct action against the Recipient or
any other person to whom the Recipient has released or disclosed the Data, to seek
damages from any breach of this Agreement or to otherwise enforce this Agreement.
(7) The Recipient agrees to destroy these Data, and all copies of the Data in its possession,
no later than 30 clays after the date shown in paragraph (8) of this Agreement, to have all
persons to whom it released the Data do so by that date, and to notify the Contractor that
the Data have been destroyed.
(8) This Agreement shall be effective for the period commencing with the Recipient's
execution of this Agreement and ending upon August 31, 2019. The obligations imposed
by this Agreement shall survive the expiration or termination of the Agreement.
Pennsylvania l ligher Education Assistance Agency

- Recinient's Business Name
b)(6)
\ ~ames L. Preston 06/17/09

----
Authorized Representative Date
President and CEO

Representative's Typed Name and Title
2
Approved as to form and legality. Approved as to form and legality.
PI-IEAA_General Counsel Deputy Attorney General
3
AMENDMENT OF SOUClTATION/MODJFICATION OF CONTRACT lt.cofJTRACTIOCODE I PA~E or PAG;s
J3"i,FFECTIVE DATE
I'
2- AMEN0MENT/M00IFICATi0fJ NO. 4. REQUISITION/PURCHASEREQ, NO. PROJECT NO. II! applicble)
001 SEP 01, 2009

6. ISSUE0 BY CODE FSA-F$2 7. ADMINISTERED BY {If other tha~ Item 6) CODE
United Stales Department of Education See Block 6
Federal Student Aid/Mission Support Group
830 First St NE • Suite 91 F3
Washington DC 20202
~
8. NAME ANO ADDRESS OF CONTRACTOR (No., streel, coU!'\lV. Staie Md ZIP Codef 9A. AMENDMENT OF SOLICIATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PA DUNS: 007368103
1200 NORTH 7TH STREET Cage Code: 41 UK7
98. DATED ISEE ITEM 11)
FINANCIAL MANAGEMENT 5TH FLOOR
10A. MODlFICA TI0N OF CONTRACT/ORDER NO.
ED-FSA-09-D-0014
K
108, DATED (6!.;E ITEM H)
CODE 00030774 I FACILITY CODE JUN 17, 2009
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICIT AT!ONS

D The abov" nurnberad solicitation is amended as set forth in Item 14. The hour and date sp,eciJied for recei.-I of Offers D is extended, D ia oot extended.
Olfers must acknowledge receipt of this amendment prior to the hour al'l<Idate specified in !he solicitalion or as amended, by a"" of 1he following methods,
<aJBv complating iIems B and 15, end raNrning copies of tha amendment: (b) l:ly acknowledging receipt of this amendment on each copy ol the o!ler aubmit1<ed;
or (c) By .,.par ate teuer or telegram which includes a 10/ararJGe to the solicitalion and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE RECEIVEDAT THE
PLACEDESIGNATED FOR THE RECEIPTOF OFFERS PRIORTO THE HOUR AND DATE SPECIFIEDMAY RESULT 1N REJECTION OF YOUR OFFER. lf by virtue of this amendment
your desire to chang~ an offer al,oody submitted, ouch change may be made by telegrnm or letter. providad each telegram or letter mekcs reference 10 the solicitation end this
amondment. and Is received proor to 1he opening hour Md dat$ specified.
12. ACCOUNTING ANO APPRCPIATION DATA (If re<iuir»d)
Modification Amount: $0.00
See Schedule Modification Obligated Amount: $0.00
13. THIS ITEM ONLY APPUESTO MODIFICATIONOF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
CHECK ONE A. TH!$ CHANGE ORDER IS ISSUEtJ PURSUANT TO: (Specify authority! THE CHANGl:S SET FORTH IN ITEM 14 ARE MADE IN THE CONIBACT ORDER
NO. IN ITEM 10A.
X B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECTTHE ADMINISTRATIVE C!iANGES (such as changes in pay;ng oflico.
appropriation dal~, ~tc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b].
C. THIS SUPPLEMENTAL AGREEMENT IS ENTEREDINTO PURS!JANT TO AUTHORITY OF:
D. OTHER (Spec,fy type of mod,lication and au1horityl
E. IMPORTANT: Contractor O is not, 0 is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organizedby UCF secl;onheadings. inc\L!dingsollcitaUon/conlract subject matlerwhere feasible.)
Summary of Modification:
(1) Incorporation of Wage Determination(s)
See Attachment A for modification details.
Except as provided herein all tmms and conditions of the dacumenl refornn<:od in Imm 9A"' 10A as Mretolorn crnlnged remains unchanged and ,n lull fore~ and elfoc1
16A. NAME AND TITLE OF CONTRACTING 0FFICEn, ,~prim\
(b)(6)
I Mike Whisler j
rnik,,. whi•d.,r""Mi -,.J
158.10NTRACT0R/0FFE.,,..R
JSignature of "8rson ,,.nho,ized tc sign)

l'q~;;;;:~01 l(b)(6)
· ISignature of Con1racIin9 Officer)
16C. DATE SIGNED
°l/1!0,
NSN 7540.01·152-8070 STANDARD FORM 30 1AEV.10.s:i.1
Previous ed,iion unusable Prescribed by GSA FAR (48 CFfil 53.243
Modification No. 001

to
Contract No. ED-FSA-09-D-0014
Approved as to fonn and legality

b)(6)
'r'.f"rnvcd
es to fo□n end lcealiu,
PHEAA Ge al Counsel Deputy Attorney General
Contract Number: ED-FSA-09-0-0014 Modification Number: 001
Contractor: PHEAA
Attachment A
The purpose of this modification is to incorporate the following wage determination by reference, in
accordance with FAR52.222-41, Service Contract Act of 1965 (Nov 2007):
(1) WD 2009-0186 (Rev.-1)
This wage determination is attached in the following pages.
All other terms and conditions remain unchanged.
200901861
REGISTER OF WAGEDETERMINATIONSUNDER I U.S. DEPARTMENTOF LABOR
THE SERVICE CONTRACTACT EMPLOYMENTSTANDARDS
ADMINISTRATION
By direction of the secretary of Labor WAGE AND HOUR DIVISION
WASHINGTON
D.C. 20210
Wage Determination No.: 2009-0186

Shirley F. Ebbesen Division of Revision No.: 1
Di rector Wage Determinations! Date of Last Revision: 09/22/2009
------~-~--------1-------------------
State: Pennsylvania
Area: Pennsylvania Statewide
Employed on Department of Education contract for loan servicing and management
services
collective Bargaining Agreement between commonwealthof Pennsylvania and Council 13,

American Federation of State, county and Municipal Employees, AFL-CIO effective July
1, 2007 through June 30, 2011.
In accordance with sections 2(a) and 4(c) of the service contract Act, as amended,
employees employed by the contractor(s) in performing services covered by the
collective Bargaining Agreement(s) are to be paid wage rates and fringe benefits set
forth in the current collective bargaining agreement and modified extension
agreement(s).
Page 1
OBTAINED BY STUDENT BORROWER PROTECTION
' CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
AMENDMENT OF SOLICITATION1MODIFICATION OF CONTRACT I' co,s

;T ID CODE I oj
PAG E PAG~s
1
' AMENOMENTiMODIFICAT,ONNO.
002
13EFFECTIVE DATE
SEP 15, 2009
4 REQUISITION/PURCHASE REC NO
I, PROJECT NO. Ill applicblel
6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY llf other thar, Item 61 CODE

United States Department of Education See Block 6
830 First St NE - Suite 91F3
Washington DC 20202
8. NAME AND ADDRESS OF CONTRACTOR lNo . street, couoty. State and ZIP Code! !XI 9A. AMENDMENT OF SOLICIATION NO.
~
98. DATED ISEE ITEM 111
TOA. MODIFICATION OF CONTRACT.'ORDER NO.
ED-FSA-09-D-0014
X
108 DATED 1SEE ITEM BJ

11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
D The above numb€red sohcrtation 1s amended as set tocth m Item 14. The hour and date spedlied for receipt of OIiers D 1se>C!ended, Dis not e>C!ended.
Oilers must acknowledge receipt of th,s amendment pnor 10 the hour and date spec,f,ed ,n the sol1crtatoon or as amended. by one of the lollow1n9 methods·
lal8y comple1,n9 ,tems Band 15, and return,ng cop,es of the amendment lbl By acknowledgmg rece,pt of th,s amendment on each copy of the oiler submitted;
or lei By separate letter or telegram wh,ch u1cludes a reference to the sohcrtat,on and amendmem numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THE
PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. 11by virtue of th•s amendmem
your desire to change an offer already submrtted, such change may be made by telegram or letter, prov,ded each telegram or letter makes reference to the sohcrtat,on and this
amendment, and ,s rece,ved proo, to the open,ng hour and date spec,f1ed.
12 ACCOUNTING AND APPROPIATION DATA llfrequore<l)

Modification Amount $0.00
See Schedule Modification Obligated Amount $0.00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14
CHECK ONE A THIS CHANGE ORDER IS ISSUED PURSUANT TO ISpec,ty authoroty) TH~ CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER
NO IN ITEM 10A
B THE ABOVE NUMBERED CONTRACT:'OROER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES {such as changes on payuog office,
appropnanon date, etc.I SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103lbl.
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF
X FAR 1 108(d)(3)
D. OTHER ISpec1ty type of mod1/,ca11onand authority!
E IMPORT ANT: Contractor D is not, 0 is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT.'MODIFICATION (Organ,zed by UCF sechon head,ngs, 1nclud1n9sohc,tahon/conlract subject matter where feasible.)
The purpose of this modification is to add the following clause to Section B 2, ""52 252-2 Clauses Incorporated By Reference (Feb 1998)", of
the contract
(1) 52.222-54. Employment Eligibility Verification (Jan 2009)
All other terms and conditions remain unchanged
Except as provided herein. all terms and condmons of the document referenced in Item 9A or 10A. as heretofore chan ed. remains unchan
15A. NAME AND TITLE OF SIGNER iTYP" or print! 16A. NAME AND TITLE OF CONTRA TING 0
Mike Whisler
President and CEO mil<<>
HiB CONTR CTOR;OffER 15C. DATE SIGNED 16C. DATE SIGNED
b)(6)
b)(6)
thoozed to s,gn)
Ci/2.S/d'; {S,gna of Contractrng ,c 0
NSN 7540-0 52-8070 ST ANDARO FORM 3 lRE 10-B3l
Prev,ous ed,tJon unusable
THE FREEDOM OF INFORMATION ACT
Prescrobed by GSA FAR !48 CFRI 53.243
'
AMENDMENT OF SOLICITATJON/MODIFJCATION
AMH!DMENTiMODIFICAT,ON NO.
•
)3 EfFFCTIVf, DATE
OF CONTRACT 11CONTRACTIDCOOE
4 AEQUISITION;l'UACHASE
• FSA090014-003
IDAG1E (JI PA~S
I'
REQ. NO, PROJECT NO ill appkbleJ
003 MAR 09, 2010 EDOFSA-10-000318
6. ISSUED 8Y
CODE FSA-FS2 7 ADMINISTERED BY llf ol~e< than l!en, 61
United States Department of Education CODE
See Block 6
830 F"1rstSt NE - Suite 91 F3
Washington DC 20202
B NAME AND ADDRESS OF CONTRACTOR I No ,

streITT, county, Stale an<JZIP Cod~)
HIGHER EDUCATION ASSISTANCE AGENCY, PA
~
9A. AMENDMENT OF SOLICJA TION NO.
DUNS: 007368103
1200 NORTH SEVENTH STREET
Cage Code: 41UK7
HARRISBURG PA 171021419 9B. DA TEO ISEE ITEM 11)
WA MODIFICATION OF CONTFlACT/ORDEA NO.

ED-FSA-09-0--0014
K
111!1DATED (SEE ITEM 13)
CODE 00030774 l FAC!UTY CODE
JUN 17, 2009
11. THIS ITEM ONLY APPLIES TO AMENDMENTS
OF SOLICITATIONS
D The above numborcd solicitatoon ,s amended as set
D
Offers must ackrn,w1edge ,ec.,.p1 of !his ~mondmeol
forltl '" Item 14 rt,e hour arid date spec,liod for roce,µt
pr,or to the hour arid oa•e specified ,n tho sohclfal<D
of Offers D
,s eKtended, Is not eXlendod,
n or as amended, by o,.,. ol the follow,ng me!hods·
I al By complet,og items 9 and 15, and return,ng
cap,eo of fhe an1endmen!; lb) Sy adno\Mec!g,r.g rece,pt
or jcJ By separate letter o, telegram wh,ch indudes~n of 1h,s am,.,,dmem on eaeh copy of trul ofter wbmmedc
ce to the sohcilahon ar,d amendment numbers FAILURE
PLACE OESIGNATEO FOA THE RECEIPT Of OFFERS Of YOUR ACK:NOWLEOGMENT TO SE RECEIVED AT
PA(OA TO THE HOUR ANO DATE SPECIFIED MAY RESULT THE
yo"' des,re to ctoaoge an otter already submmed, sud, IN REJECTION OF YOUA OFFER 11by virtue of this
char.ge may be made by talegram o, letter, proV1ded amer.dment
ame,odment, and is rece,ved poo, to Iha open,r.g hoor each telegram or le lier ma~es refo,ence to rt;o sol.::ot~UO
aM date spec,f,ed. n and Ihos
12 ACCOUNTING ANO APPROPIATIO .. 0ATA (ff ""'lU'fM)
Sea Schedule Modification Amount: $2,382,895.10

Modification Obligated Amount: $2,382.895.10
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF
CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO AS DESCRI
BED IN ITEM 14
CHECK ONE A, THIS CHANGE OROEA IS ISSUED PURSUANT TO: iSp,,c,ly
au!hw!y) THE CHANG~S SET ~ORTH IN l[EM 14 AAE MADE IN THE CONTRACT OROEA
tW. IN IHM JOA
8. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED

TO REFLECT THE AOM!N!STRA TIVE CHANGES I such
~pprop,oanon date, otc J SET FORTH IN ITEM 14. PURSUAN as chaoges "' pay<r>gofflco,
T TO THE AUTHORITY OF FAR 43 103/b).
C THIS SUPPlEMENTAL AGREEMENT IS ENTERED INTO
PURSUANT TO AUTHORITY OF:
D. OTHER ISpeco/y type o! mod1l,eat,on and author,ty)

X Funding only action.
E. IMPORT ANT: Contractor O is not. 0 IS required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENOMENT/MOOIFICATION (Oryan,zed by UCF secuon headings, mclutiing sohcolabo
n/COnlraCI subi9ct matter where feas,ble.)
The purpose of this modification is to add funding in the

amount of $2,382,895.10. Please note that these are American Reinvestment and
Recovery Act (ARRA) funds.
The current not~to-exceed limit is increased by $2,382,895.10

from $5,000,000 to $7.382.895.10.
All other terms and cond1f1onsremain unchanged.
Ettop!as provided herom all terms aM cond,trons of the document

relereoc~d"' Item 9A or 10A as heretoto,o ctoanged mma,ns unct,d<>g
1SA. NAME AND TITLE OF SIGNER !Type or print! ed and"'
fuH force and eff~ct
16A NAME AND TITLE OF CONTRACTING ~~
or pr.o!)
Matthew D. Sessa, Program Director
Mike Whisler t
,; mike whisler@ed.g
b)(6) 15C.DATISIGN~. .
1SC DA TE SIGNED
fb)(6)
I
NSN 7540-01 152-8070
P«Muus eU,toon uo1usable,
"' /Sjgnature UT Cont,acMg OtflCNI
ST ANOARO FORM 30
1/,,11~
IREV. 10 B3J
Prescnt>e<Jby GS/\ FAA 148 CFRI 53 243
• •
MODIFICATION NO. 003

ro
CONTRACT NO. ED-FSA-09-D-0014
Approved as lo fonn and legalitv Approved as to fonn and legality

b)(6)
. Jb)(6)
PIIEAA I"' era! Counsel Deputy Attorney General 7 I
'
AMENDMENT OF SOUCITATJON/MODIFICATION
AMENDMENTIMOOIFICATiON NO.
•
!3. EFFECTIVE DATE

OF CONTRACT r
4. REQUISITION/PURCHASE
•
CON!RACTIDCODE
FSA090014-004
I PAG1~ or
PAGt
I'
AfQ, NO PROJECT NO. flt appl1cblel
004 MAR 09, 2010 EDOFSA-10-000325
6. ISSUED BY
CODE FSA-FS2 7. ADMINISTERED BY llf 01her th;m ltern 6/
United States Department of Education CODE
See Block 6
Washington DC 20202
8. NAME ANO ADDAE.55 OF CONTRACTOR (No, str<tet,

county, State and ZIP COOel
HIGHER EDUCATION ASSISTANCE AGENCY, PA
DUNS: 007368103 ~ 9A. AMENDMEN/ Of SOLICIAflON NO
Cage Code: 41 UK7
HARRISBURG PA 171021419 gB DA TED ISEE ITEM 111
JOA. MODIFICATION OF COITTAACT/ORDER NO.

ED-FSA-09-0--0014
CODE 00030774
' 100. OATEO (Sl,E ITEM 13)
J FAC(LIJY CODE
JUN 17, 2009
D The above nlJl'lbered sohc•tanoo •• a,no,,.,ted as sel forth"' Item
14. The h<>Ur..,,d dale speciflfi<l for ,eceipt of OHers D D
,s extonded,
otfers must acknowledge receipt of thos amendmen1 poo, as no1 exlendod.
10 tho hour and date spoctfl&d m the sohcot1'1,on Of as arnende-d.
lei By completing l!<>mS0 and 15, and retum«,g by one of the following methods·
copies of !Ila amendment; lbl By ac~oowledgmg recejpt of
o, lei By separate tener or telegram wh;ch 1nclude~e thi$ MJ1endment oo each copy ot the offer subm,tted;
to the sol,citat,on and amendmerot numbers. FAILURE Of
PLACE DESIGNATED FDA THE RECEIPT OF OFFERS PRIOR YOUR ACkNOWLEOGMENT TO BE RECEIVED AT THE
TO THE HOUR ANO DATE SPECIFIED MAY RESULT IN REJECTIO
yo<N de,sjr,, to change an off a, alreMy ,ubmmed, such change N OF YOUR OfFER. lf by virtue ol 1h,s amern:lment
may be made by telegram o, tener. provided each 1el&grem
amendment, and is received p,,or to !lie opemng hoor and or letter makes reference to tho sol,o,tation and th'5
date specified
1Z ACCOUNTING AND Af'PROPIATION OATA 11r,oqu,rod)
Modification Amount: $3,783,500.00
See Schedule
Modification Obligated Amount: $3,783,500.00
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRA
CTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED
IN ITEM 14
CHECK ONE A, THIS CHANGE ORDER IS ISSUED PURSUANT TO: ISpec,fy
avthorrty) THE CHANGES SET FORTH IN ITEM 14 ARE MADE
NO. IN ITEM 10A tN THE CONTRACT ORDER
8. THE ABOVE NUMBERED CONTRACTiOROER IS MODIFIED

TO REFLECT THE AOMINISTII.ATIVE CHANGES Isuch a~
bppropnauon date, etc I SH FORTH IN ITEM 14, PURSUANT el1angas ,n pay,ng ofhce,
TO THE AUTHORITY OF FAR 43 103Ib),
C THIS SUPP!.EMENTAL AGREEMENT IS ENTERED INTO PURSUANT
TO AUTHORITY OF:
0 OTHER (Specoty type of modi/lcat,on

X Funding only action.
and duthority)
E. IMPORTANT: Contractor D Is not, 0 is required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Orgamzed by UCF sectoon haadongs, 1nciud1ngsohcotabon
/rontract subject maNer where feasoble.)
The purpose of this mdification is to add funding in the amount

of $3,783,500.
The current not-to-exceed limit is increased by $3,783,500 from

$7,382,895.10 to $11,166,395.10.
E~ccp1 IIS provided here,n all terms i>nd cond<t,ons of the

document rnlerenced in Item 9A o, 1OA as heretofore change<! remains unchanged
15A. NAME ANO TITL£ OF SIGNER !Type or pnnll and ,n luH to,ce and effect
1 6A NAME AND TITLE OF CONTRACTING OFr,,.,_\
or prontl
Mike Whisler
Matthew D. Sessa, Pro< ram Director mike.whisleri,i\ed.aov/ /\
(b)(6)
,gn)
1SC. OATf SIGNED
rb)(6)
1s,gna1uro of Co'ltract,ng
~
Ott,cerl
.eJ lf\T~IGrE;
6
NSN 7540-01-152-8070
Prnv,ou.s <ro,uon unusable STANDARD FORM 30 !REV. 10 BJJ
Prasniboo by GSA FAR 14B CFRI 53 243
SCHEDULE Continued
ITEM J,jQ. SUPPLIES/SERVICES QUAJ,jTITY
"'" UJ,jlT PRICE $ AMOU,,.T J

0202X2010A2010.ENB00000.6A4.2572A.MG.000.000,
000000
Cost Applied: $3,783,500.00
(New Line Item)

0003 Title IV Student Financial Aid Servicing
1.00 SE 3,783,500.00 3,783,500.00
PAGE 2 OF 2
• •
MODIFICATION NO. 004

To
CONTRACT NO. ED-FSA-09-D-0014
Approved as to form and legality Approved as to form and lcgalily

rb)(6) I b)(6)
3 /(. 10
PHEAA Genedi Counsel Deputy Attorney Genera
Memorandum
------ ~
Date:
____ A_p_,_,1_1_,_2_0_1_0
_______ ----·===-·---=========~--
-_ -_
-_
To: File
----------------------------------
Program: Title IV Additional Servicers (TIVAS) - ED-FSA-09-D-0012 through -0015
I
Contractor(s): Great Lakes, Nelnet, PHEAA,Sallie Mae
Subject: Cohort Default Rate (CDR) Challenge Support- Basis for Common Pricing Structure
The purpose of tris memorandum is to document the process and rationale utilized in arriving at the
negotiated common pricing for CDR Challenge Support.
On February 2, 2010, the Government requested an impact analysis in response to CR# 827 for CDR
Challenge Support. The Government received high level approaches, including anticipated Level of Effort
(LOE) and ROM pricing associated with meeting this requirement. A summary of LOE responses are
provided below:
... --
TIVAS Per Institution I Per Borrower
(Hours) (Hours)
Great Lakes b)(4)

b)(4)
- r ~
Nelnet
~ r ~
PHEAA
- ~ r ~
Sallie Mae
'
- ' I
Based upon the information provided, the Government believed that a reasonable LOE assumption
associated with this support would be 6 hours per institution, and 30 minutes per borrower. On
February 23, 2010, the Government presented this to each of the TIVAS, and requested a proposal
including a fixed price per institution researched, and a fixed price per borrower researched.
On March 8, 2010, the Government received the following proposed pricing:
TIVAS Per Institution Per Borrower -·7

Great Lakes b)(4) (b)(4)
IN--,-,,-,-,--
'
k:E_A_A____ .,..-l
7
Sallie Mae
'·---- ~-------~-- ----~
The Government identified a broad variance among the pricing proposed. This is a result of the
utilization of different labor types among the TIVAS, as well as varying geographic location of the TIVAS'
operations. Though an IGCEwas not developed in advance, the Program Office validated that the
proposed hours and rates for CDR challenge support was consistent with their technical experience and
historical information.
Consistent with the tenets of the TIVAS contracts, the Government intended to establish common
pricing for this SLpport, as communicated up front to the TIVAS. In establishing the common pricing
structure, the Government compared initial proposed pricing under the TIVAS contracts, and compared
that to the final common pricing model. The Government applied the variance to the proposed pricing
under the CDR Challenge Support, and averaged out the price among the four TIVAS on a per institution
and per borrowec basis.
The resulting common pricing structure is provided below:
I CDR~-1-~~-S--l--Pe_,_'_"_"_''_"_'_'o_,_;__'_'_'_Bo~r.::::_
$213.00 $23.00
Challenge
I Support·--~-------"'------~
The Government presented the pricing to the TIVAS on March 17, 2010. By March 23, 2010, all four
TIVAS provided confirmation of their acceptance of the common pricing terms above, which reflects the
final negotiated pricing.
As a result of negotiations, the Government was able to achieve savings of 37.03% on the per institution
unit price and 30.58% on the per borrower unit price, both from the average proposed price among the
TIVAS.
The Government does not anticipate significant utilization of CDR Challenge Support at this time. Based
on historical information, the number of challenges anticipated is approximately 0.25% of the borrowers
in the cohort.
(b)(6)
I
•
Michael Whisler
Contracting Officer
Federal Student A.d
April 1, 2010
AMENBY
OBTAINED DMEN T DF
STUDENT SOLICITPROTECTION
BORROWER
2 AMENDMENT/MODIFICAT10N
ATION~FIC CENTER
ATIONAND AMERICAN
NO
FEDERATION OF TEACHERS
OF CONT 0 UNDER THE FREEDOM OF INFORMATION
3 EFFECTIVE DATE
RACT
PAGE PAG;s I'' ")1'°
ACT
CODE
j
1
oj
4 REOUISITJON/PURCHASE REQ NO
PROJECT NO. (JI apphcbl11)
6. ISSUED BY
005

CODE
MAR 24, 2010
FSA-FS2 7. ADMINISTERED BY (If other than Item 61
I' CODE
See Block 6
Washington DC 20202
8. NAME AND ADDRESS OF CONTRACTOR 1No.,

street, county, State and ZIP Code!
HIGHER EDUCATION ASSISTANCE AGENCY, ___01_9A. AMENDMENT OF SOLICIATION NO.
PA DUNS: 007368103
Cage Code: 41 UK7
HARRISBURG PA 171021419 9B. DA TED ISEE ITEM 11)
10A. MODIFICATION OF CONTRACT/ORDER NO.

ED-FSA-09-0-0014
K
108 DATED (SEE ITEM 13)
CODE00030774 IFACILITY CODE
JUN 17, 2009
11. THIS ITEM ONLY APPLIES TO AMENDMEN
TS OF SOUCJTATJONS
D The above numberad sohcitat,on ,s amended as
Offers must acknowledge rece,pt of th,s amendm
set forth ,n Item 14. The hour and date specif•ed
ent prior to the hour and date specified m the sohcitat,
for receipt of Offers D ,s extended, D,s not extended.
(aJBy completong nems B and 15, and retum,ng on or as amended, by one of the foHowong methods
copies of the amendment: (b) By acknowledging ,
or (cJ By separate letter or telegram wh,ch inc/ude~ rnceipt of this amendment on each copy of the otte,
nce to the so/,c,tation and amendment numbers. FAILURE submitted;
PLACE DES/GNA TEO FOR THE RECEIPT OF OFFERS OF YOUR ACKNOW LEDGME NT TO BE RECEIVED AT THE
you, des,re to change an offer already submitted, PRIOR TO THE HOUR AND DA TE SPECIFIED MAY
such change may be made by telegram OJ letter, RESULT IN REJECTION OF YOUR OFFER. If by vfrtue
amendment, and is received pnor to the opening prov,ded each telegram OJ letter makes reference of this amendment
hour and date specified. to the solic,tat,on and th,s
12 ACCOUNTINGAND APPROPI/\TION0/\T/\ (lfrequ,re
~J
See Schedule Modification Amount: $0.00
Modification Obligated Amount: $0.00
13. THIS ITEM ONLY APPLIESTO MODIFICATIO
NOF CONTRACTS/ORDERS.
IT MODIFIESTHE CONTRACT/ORDERNO. AS DESCRIBED
CHECK ONE
IN ITEM 14.
A. THIS CHANGE ORDER IS ISSUED PURSUANT TO;
(Speedy authomy) THE CHANGES SET FORTH IN
NO. IN ITEM 10A. ITEM 14 ARE MADE IN THE CONTRACT ORDER
B. THE ABOVE NUMBERED CONTRACT/ORDER IS

MODIFIED TO REFLECT THE ADMINJSTRA TIVE
appropnation date. etc.I SET FORTH IN ITEM 14. CHANGES (such as changes ,n pay,ng omce,
PURSUANT TO THE AUTHORITY OF FAR 43. 1031b).
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERE
X a mutua l agreement of parties.
D INTO PURSUANT TO AUTHORITY OF,
D. OTHER (Spac,fy type of mod,ficat,on and authomy

)
E. IMPORTANT: Contractor O is not, 0 is required to sign this document and return

copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION
(Organ,,:ed by UCF sechon headings, includmg solrci1at
ionlcontract subject ma11erwhere feasible.)
The purpose of this modification is to incorporate the

attached terms for Cohort Default Rate (CDR) Challe
nge Support activities.
hcept as provided here,n, all terms ar,(I condition

s of the document refereo,ced m Item 9A or 10A.
15A. NAME AND TITLE OF SIGNER !Type or print! as heretofore changed. rema,ns unch ed and ,n lull force and effect.
16A. NAME ANO TITLE OF CONTRACTING O FIC
IType or print!
Mike vVhisler
mike.whisler ed.
15C. DATE SIGNED
b)(6) 16C. DATE SIGNED
! /:,_r-/,c
OBTAINED
NSN BY STUDENT
7540•01-152•807 0
onuact,ng
BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
ff1cer) f ( 10 to
Ari"'"" 1,n,,ut-,1.,
P,.,vor,,,~ STANDARD FOAM 30 /REV. 10.aJJ
PrP~rc,N>,1 hv r,<:lo ~,.., •~~ r~,,. ..,,..,
~~
• •
COHORTDEFAULTRATE(CDRJCHALLENGESUPP
ORT
TERMSAND CONDITIONS
FSACCRID #827
TIVAS CDR Challenge Support Pricing

Description Unit Price
Institution $213.00
Borrower $23.00
Assumptions:
1. The prices above are fixed-unit prices for

supporting CDR challenges in accordance with
the
attached Statement of Objectlves (S00).
2. Both Institutional and Borrower Unit fixed-unit

prices shall apply.
3. An Institution is defined as a school or branch havin

g a unique school code/ID as established by
the U.S. Department of Education.
4. A Borrower is defined as an individual with a uniqu

e SSN.
5. Each TIVAS is responsible for loans that were servic

ed by that TIVAS under its contract with the
U.S. Department of Education.
6. No development/enhancement costs shall be paid for activities associated with

meeting the
requirements in the attached S00.
7. Escalation will be handled in accordance with

the escalation methodology in Section B.13(N)(4)
of the contract.
8. CDRchallenge support services shall be operational

no later than March 31, 2010.
Title IV Additional Servicers (TIVAS)

Page 1 of 2
• •
COHORTDEFAULTRATE(CDR) CHALLENGE
SUPPORT
STATEMENTOF OBJECTIVES(SOO)
FSACCRID #827

The TIVAS shall support the functions curre
ntly performed by the Guaranty Agency and/o
defined in CFR34 § 668 Subpart M and the r Direct Loan Servicer as
Cohort Default Rate Guide in the role of Data
reporting requirements to the Department Managers (including
as detailed in the guide Chapter 3.3) in respo
to draft and official cohort defau nding to school challenges
lt rate notifications.
Reason for Change:

FSAis prepared to release its draft (and ultimately
its final) Cohort Default Rates. Schools have the
challenge the status of a particular right to
borrower as being in default on several groun
supporting the challenges has traditionally ds. For FFELloans the role of
been filled by the GA. Given that the loans
under ECASLAare no longer part of the GA's that the Department owns
portfolio, FSArequires support in processing
the challenge process.
Title IV Additional Servicers (TJVAS)

Page 2 of 2
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1

1 CONTRA;;T 10 CODE I 1
?~,,;s
FAGE •.JFI
Pi10JECT r,o.!I( ar.r'•cb·e:·

2 Ar,1EMc)ri,£NT,r,>OO;flU,T,,Jl·i NO
006
13ff~~~~/~;,A;~10
->.REOL:ISITION.VUfiCtiASERE•J, !10
7, ,\Or.:1111STfflED ff{ !If othe, Ohan hem 6:•

I'
,_) •~Sl/4D b( CUDC FSA-FS2 COCE
United States Oepr\me:.t of Education See Block 6
Federal Student AidlMISSIOll Support Group
830 First St NE· Su,le 91F3
Washington DC 20202
8 c:AM:CAND AIJ0flfS5 Or CONTRA'.'.:!Ofl{Ne,.. st,eer. c~"ntv, S:a;e and ZIP CuJe) ~ 9/J.. AMENDt~nn or SO"ICIAI ION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PA DUNS: 007368103
12CO NORTH SEVENTH STREET Cage Code: 41UK7
9~. DATED ISEE ITEM 111
H.l\.RRISBURG PA 17HJ21419
10A. MOOlrlCAll:JN Of COMTftACT,Olllllh MO
ED-FSA-09-D-0014
K
103 ;)ATEO(SE;[ITLM IC,)
)FACILITY CODE JUN 17, 2009

COC·E 00030774
D Teie obo•,e ~umbe<ed sc,l1~1rn\iunis amended as set tcrth in Item 14 The hour and date spec,t,ed 101,eco p of Offers D 1s txt~Mcd. D
,s not e,te~ded.
OIiers must ackncv,le<'Je receipt ~r th,s a<nendment f""" to ,he hD\J! and date spe~of1edin the solicitation or dS amended, by one o! the following me1hods:
ialB·, completing ,1ems 3 and I&, and returning ___ copies of the arnendmon1; ibl By acknGwled;iing rece,µt ol this arner1cinwnt on each copy of 1I·.eoffer sutrn'ned;
er re) By srrwale iftoc, o, teleg,orn which ,ncludes ~ ,e!e<ence 10 tl-.e soi,ci,aticn and amendment num~e,s FAILUREOF YOU'1 ACKNOWLEOGMENl TO BE RECff✓tt:: AT THE
rLAC:t DESIGl,ATE:l FOR 1 Ht RECE,PTOF OFCU'.S PfUOR -.o1 H£ HOUR AN[) DATE SPECIFIED f,1AY RESULTIN REJECllON OF YOUR OFFER. I( by v,n~e of this ameodrntnl
"'"' Jus,rc to cl1ar:~e un ulrer already suOmUeJ, such ct,ar,ge ma; be made b'/ telegram c,r iette<, p,ov,ded each telegram er le!ter niakes rMerence lo!~~ ,~•k1ta"on and lhos
amenco1,en,. an~ ,s «,;:;e1-:e,:f
rHwr 10 the o;:,en,ng l\our a.1d data spec,t1ed
Modification Arnount: $0 00
See Schedule Mo,j1fication Obl1ga:ed Amount' $0 00
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS.

IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED Ir<ITEM 14
Cliff~ UNE A. THIS CHAl·JGE UliOlll IS ISSllfD PUfiSUArH 10: ISpec1iy aulho"!tl fHE CHMlGES S[T FOFlTHIN ll'tM 14 ARE MADE IN THE CCI-HRACl OR0Cf1
NO Ir< t'I EM 1O,\
6. TH~ AEiOVLl.'Ul,foEEEOCON"ifiACT!OHDEftIS t,\UOli'IED to REHECT THE ADMINISTRAl lVE CHANGE:~Isuch as changes in p~yi~g ofhce,
app,oprrnucn date, e1c) ~ET FO/HH IN ITEM 14, PURSUANT 10 r~1EAUTHORITY OF FAR 43.1031!>).
C 1 Ci!SS'JPPLE,\lEJH AL AGREEMENT IS ENTER£DINTO PURSUANT TO AUTHORllY OF:
X a mutual ccnsent of parties.
D. OTHEi1 !Spec,ly !)'Pe of rnQd,(,ca\10'1 anJ authc 0,01yl
E. IMPORTANT: Contractor D Is not, 5) is required to sign th,s document and return copies to the issuing office.
1·~. DESCRIPTION Of--AMENDMEf\1TiMODIFICArlON (Organl7.ed by UCF sGction headings. ;nciud:ng sohcitation/cc:miractsubjecl matter whew (Msib:e )
The purpose of this modification is to incorporate Task Order 003. Processing of Borrowers Greater Than 360 Days Delinquent. in accordance
with the attached Statement of Objectives (SOO) and the terms of the base contract
All ctlier terms and cond1t1ons remain unchanged.
;GA IJA)Jlf' ,\ND TITLEOF SIGNL"R!T~µe "' Imn1I 1GA. ~AME AND TITLE OF CONrnACTiNG o; F"IC(R!Type er ~""ti
Nicholas Chung
202-377-3635
l(iC. DATE SIGNLO '6C. DAll SIGM'fC
I I
s}'jJo (S191 rac,.fI~ f'ice•J 7 s/=(10
l!SN 7540-0 l -15~-60/0
STANDARD FOAM 30 1REV.10-~~,
P,osc"b~d by GSA FAR (~6 CFfll 53 :<lJ
f',e·,im,s e,JHonnJnusable
• •

Processing of Borrowers Greater Than 360 Days Delinquent
Statement of Objectives (SOO}
Task Order 003
Objective
The Servicer shall accept an on~system transfer of borrowers that are greater than 360
days delinquent and complete an off-system transfer of those borrowers to the Debt
Management Collection System (DMCS) shortly thereafter.
Considerations in achieving this objective may include, but are not limited to:
• DMCS File Size

• National Student Loan Data System (NSLDS) Reporting
• Financial Management System (FMS) Reporting
Pricing
Borrowers falling within this task order shall be billed as unique borrowers at the same
deliverable status rate defined as, "Borrowers 270+ Days Delinquent", in accordance
with Section 8.13.N.3 of the base Contract. These borrowers shall be uniquely tracked
and identifiable for audit and invoicing purposes.
!n addition, if DMCS rejects borrowers transferred pursuant to this task order at a rate
that exceeds the reject rate of the Servicer's DMCS subm!ttals under the base Contract,
the Servicer may bill for activities stemming from such rejects at a mutually agreeable
price
Allocation Methodology
Loans processed under this task order will not be included in the default rate calculation
provided for in the base Contract.
Credit Reporting
The Servicer shall not be required to perform credit bureau reporting with respect to
loans transferred pursuant to this task order.
All other terms and conditions of the base Contract are applicable and incorporated
herein.
[End of Document]
•
• PACSI'8,- Pt.C;EC
__ I__ ,_
3 HfE,'.:Ti':E 0~ T~ Me :(CT '10, n, eppl"'""
C07 . MAY 19. 2010
;,·1:'.~~[Cc,,,,.,----- ''
1 7.'F's'2'
··-----,----,,.,,,,,,LF's'A _____ , 1 AC,r•.BtJ!SH~rn0Y Ill ,.,i,.,"""""""' 01
CO02
Un,teJ Si<1leo D<:par!mr:nt of Educa(j._m See Block 6
~eckr;;i Studenl ~\,JiM,~s,on Support Group
i!J•J Firs! St l~E - Su1(e 91FJ
,'la,;h1n9to,1 DC 20202
----========---------~-------~--------------------
e 0.N,IC ,,,',() ,;t,L•;-:[sS iJF COr!lf',"~lOH (No, .;ireet, c0umy S1ate .,nd ZIP C<1dol _(XI ~A MACtJJM[NT O> 50L,C.1,\Trm; r«)
i·l:\~~l:P f:.JUCA T!Cfl ASSISTJ.NCfC AGENC'r'. PA DUNS· OO7'.>6810'.l
1200 NOPTH SE'.iEhTH STREET Cc1ge Code: 41UK7
H/. RR1i;LlLl\r; P,\ 171021419
rnA i,1cn,r1r.A 1;0« Of C.Q.~lPACT.'0f1l>tF ",)

EO-FS/,-09-0-0014
X
I F,\CILITY COD( JUN 17, 2009

11. THIS lrEM ONLY APPLIES TO AMENDMl:NTS OF SOLICITATIONS
D "" a•,~•e ,c.ir,,;,o,,eJ "'''"'""o",; i>'ner•fod a,""' fo,ohm l1e01 14. The l">Ufand date wecihcd (or ,ece,~! ol 0/fe,, 0.,
c,teede~, 0
i, otot exleo,dcd.
GIie,, '""" eckn&•,,leOge ,ecei;;t ol thi, amon1on.eott r,.o, to th• hour an~ da,e sp,c,lled in tt.o sol1cila1ion or., nmended, b\· one ci ohe lollow11,g,.,ellv,dc.
,.,1c·,, cco,,01c•,,7~ ,tom, e ,.,d
15, and ret•;<1;ir.g copoe, al the arroodo,on,; :t: By ac~nowlod9,o1Q roco,pt of u~, ,mendrnonl on e,,ch cop;,;( mo o1ior ,u~e>1t1•d.
01 :,,- o, ,,,porace ICIW Cf teie9·om wh,ch iocl,de, a ,o:e,ence ,., the ,o,.c,,,t,on ood ameMmem nurncors. FAILURI; Of iOUfl ,\CKNO'NlEOGMENf TO 6C l<ECEl'cfc' AT OH!"
f'I ,1.;1. C:,[$:~•1,\TCO f OR ltl~ RC<;!:Wl 'Jf OFI msrrn◊fl TO TlrE Ii OUR ANO OAT[ £Pi:CIFIW MAY RCSVL.TltJ liU~CTl'JtJ Of YCU~ Uffl;l1 ,1 Cy v,,"lUe ol ''·" an;e,-,urr,cr,(
;uer """"' tc ,,. ,,.·,~c .,., crier ,.1,eo~·,· worn,110C, """' Cl>ang• may :>emado b·, leiegr,,m or ,ene,. p<o--iclodeach tolcg,,;,n oc letw ,no~<s ,,fo,.,noe to ""' ool,c,ta,.,,,. >c,d ""-
,,,,·,e,•d•»o• ,1, a,,d ,; rece,·, d ""''' W ,c., c,oon,nu lvo,., ono Cato SJ>e«f1od
·;:;-,::::_
,_,,,m""G "''°A~,-l<G~•"' •CN o,,I,\'" ,eo,,.od/ t,iodificatiori Amount: $0.00
Sve Schedule Modification Obligated Anwunl· W 00
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTHACTS10ROERS
IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN IT!:M 14
CHEC~ o,1E A THIS CHANGf onorn ,s ISSUlD PURSUANT TO: ,S~edy .,,tl.01,,v) THE CrlAtlGES SH FORTH IN Hi'M 14 ;.nE MADE IN THE coinr.110 om:.,~r,
no, IN IHM 10A
5 frlE ~BOI/[ NUMOERfO CONTRACTl◊l"ID[li IS MOO,fU;Q TO llErlC'.;T THE AOMl1Jl$THATI\/E CHMJGLS lsuch as choo,gc., <,po,;ng ~l'ice,
oppc•P"•'""" ,1,,to. otc./ SH FORTH 111ITEM 14. PURSUANT TO TkE AUTkORITY ('F FAR 43 1031~1-
The purp~-se of lh1s mod1f1cation 1s to replace the Contracting Officer"s Representative (COR) des,gnated iri Section B. 13.M of the conlract ii$
fcl:mvs, effective 1mmed1alely:
r,rr ;-'.,-,akciApp,c:ih
h:de,ai S!udcnt Aid
3 00 f'11st Sir<NL r~f. Su1!<c>6104
'/,'a~h1n9lon. DC 70202
!C:;1,_,,i_k·:rnku a;:,µ,a~.rQ!ed gov
~'lrnne ('.::02: 377-3723
A •:opy of Mr /,pp1cih"s COR .j6signat1on let(er and COTR cer1jfir:a:ion lelter are auach,cd herem. All other terms and corid,horis rerna,n
L.nchilnciwl
-\bJ(6)
I I
•
f,'~/; ·,,,.,J.-): 1:,:;+~·.-,, ST ANDA RO FORM 30 ,Ri''•'·,c-B;,
f\s.o~~, ""'""'' ,.c-u;,;1,•e P,e,c,,!l,d b, GSA >'Ml 146 :·1n1 SJ 2.,:
• •
MEMORANDUM
U. S. DEPARTMENT OF EDUCATION
OFFICE OF FEDERAL STUDENT AID
ACQUISITIONS GROUP
To: Kwaku Appiah

Contracting Officer's Representative
From: Michael Whisler
Contracting Officer
Date: May 13, 2010
Subject: Designation of Contracting Officer's Representc1tive
Contractor: Pennsylvania Higher Education Assistance Agency (PHEAA)
Contract Title IV Student Loan ManagemenUServicing (TIVAS)
Services:
Under the provision of Contract No. ED-FSA-09-D-0014, dated June 17, 2009, awarded to
Pennsylvania Higher Education Assistance Agency (PHEAA).
1. This is to certify H1atKwaku Appiah, FSA Business Operations Group, is hereby

designated as a Contracting Officer's Representative (COR) for the above referenced
contracts.
2. This designation will remain in effect from execution of this letter through contract
termination, unless sooner terminated m writing by the Contracting Officer or successor,
or by reason of your reassignment, resignation or termination.
3. The Contracting Officer is to be notified 1mmed1ately 1fyou receive notice of

reassignment, or when you will be absent for an extended period of time or otherwise be
unable to fulfill the responsibilities of this position. In your absence, notification is to be
given by your immediate superior. You are required to maintain current COR certification
in accordance with program requirements. Details may be found on the OCFO/CPO
website on ConnectED.
4. AUTHORITY AND DUTIES: You are hereby authorized by this designation to lake any
and all action with respect to the following which could lawfully be taken by the
Contracting Officer, except any action specifically prohibited by the terms of the subject
contract and paragraph 5, "LIMITATIONS, of this designation.
a. To monitor and to assure that the Contractor performs the technical requirement
of the contract including inspection and testing of deliverables and evaluation of
reports in accordance with the contract terms, conditions. spec1f1cat1onand
drawings. Assure any inspections performed are necessary to assure compliance
with all contract technical requirements and require the Contractor to correct any
deficiencies. Upon technical acceptance of completed work for FSA. complete a
record of inspection and acceptance. When reports /forms are prepared assure
they are forwarded to the Contracting Officer.
b As the mdividual named in the contract as the COR you are the sole pe1·son
(other than the CO), after clppropriate coord1nat1on with the PM, wtltl the aul~1011:y
to communicate technical direction, and to recommend final acceptance or
rejection to the CO.
COR Designation Letter
•
Contract No. EO-FSA-09-0-0014
TIVAS - PHEAA
•
c. To establish and maintain appropriate record-keeping files, in accordance with

FAR Subpart 4.8.
d. To review, evaluate and comment on any aspects of the contract and its
performance to include problem areas. proposols, and technical issues. and to
make written recommendat1ons to the Contracting Officer.
e. To communicate cmcJcoordinate directly with the Contractor to the extent

necessary to carry out your duties as COR except as prohibited 1n paragraph 5,
'·LIMITATIONS" of this designation.
f. To attend post-award, pre-construction, negotiation, and other conferences.

Assist and participate in the post award orientation.
g. To coordinate site entry for Contractor/Government personnel as appropriate.
h When site visits are conducted, compare actual accomplishrnents with sct1eduled
and report performance. Be alert to changes in technical performance that may
affect the financial status, personnel, or other elements of performance.
i. To assure that Government Furnished Property (GFP), if provided in the contract

(including software), is available when required and proper documentation is
obtained when such property is transferred. Review lt1e contractor's property
control system and softv,are configuration management to ensure compliance
with Government property clauses and recommend to the CO either approval or
disapproval of the system.
j. To ensure accountability of GFP and Contractor Acquired Property (CAP) is

established upon receipt of the property and an audilable record of ownership 1s
maintained (Leased Property must be included). Ensure that all Government
property, whether government furnished, contractor acquired, leased or
contractor fabricated is properly labeled and identified and that the department
asset management database is updated.
k To monitor the acquisition, control, and disposition of Government Property by

Government personnel and by the contractor. Assess contractor for any loss,
damage, or destruction of property. To verify maintenance activities are
performed.
I. To ensure the contractor in accordance with FAR Part 45 conducts accurate and
timely periodic inventories according lo established schedule approved by the
Property Administrator, as applicable. Have the contractor submit electronic
reports indicating the results of the inventories performed. Document upon
discovery any discrepancies or upon identification of misuse or loss and resolve
all discrepancies.
111 To provide appropriate notification to the Contracting Officer in any instance

when his/her immediate or expeditious dec1s1onis required. Immediately
reporting contractor performance problems to the CO/CS.
n. To prepare a wntten evaluation of the contractOl"'s performance within 45 days

after completion of any contract year in accordance ''Perforrrnng Contractor
Performance Evaluation (C0-107)" on connectED.
Page2of5
•
TIVAS - PHEAA
•
o To provide to the Contracting Officer sufficient evidence of a breach and

suggestion for an appropriate contract remedy, 1fd breach of contrcict is 1dentifiecJ
and assist in evaluating contractor response
p To assist the CO in determimng whether to terminate a contract_
q. To review progress and financial reports, invoices, vouchers, and recommend

approval or disapproval by the CO. To enter receipts into the Contract and
Purchasing Support System (CPSS) after review invoices/vouchers. In cost-
reimbursement contracts exceeding $100,000 estimated value, verify
conformance with the clause ·'Payment for Overtime Premiums'"_ Also
recommend approval and disapproval of overtime in Labor-Hour or Time-and-
Material contracts. Review and make timely recommendations to the CO as to
the approval, disapproval, or other action to take concerning a contractor's
submission of (or failure to submit) payment requests, deliverables, interim or
final progress and financial reports, or any other requirements of the contract.
Maintains a record/summary of payments to date to ensure that short-term
progress is viewed as part of the whole to help monitor payment expenditures
against total obligations.
r. To maintain all necessary records to document and describe the performance of

your duties as COR, and to distribute such records as applicable.
s. To provide advice and assistance to the Contracting Officer in other areas of

contract administration which are not specifically covered in this designation
Keep the CO informed of all communications with the contractor in order to
prevent possible misunderstandings or situations that could become the basis for
future claims against the Government Only the requirements written in the
contract can be asked of the contractor. If additional requirements seem
necessary, discuss them with the CO and PM, but do not try to enforce them
unless the CO modifies the contracl m writing.
t. To review and recommend in writing contract modification requests or changes to

the SOW and period of performance necessary to accomplish the objective of tt1e
contract. Prepare a technical evaluation to support a determination that the
change is not outside the scope of the contract. For contractor initiated changes,
direct the contractor to submit a written description that includes the effect of the
changes on the contract terms and conditions Review the submission and send
it to the CO with your recommendation.
u. To recommend, in writing, to the CO whether an option should be exercised

under the contract (given a contract awarded with options and an option clause).
Submit market research data to the CO to support the recommendation to
exercise the option.
v To submit procurement request for additional services/tasks.
Page 3 of 5
•
TIVAS - PHEAA
•
w. To assist the CO, 1fasked in administering Stop Work Orders.
x To notify the CO about a delay in the delivery or performance schedule under the
contract.
y. To assist the CO in analyzing a claim, recommend settlement position, and

participate in the resolution process.
z. To advise the CO at the complet1on of the contract, as to the receipt of all items,
services and reports required under the contract and the compliance with all
contract provisions. Also, recommend a disposition of any Government
Furnished/Contractor Acquired property in the possession of the contractor, and
verify the usage of any Government-owned consumable furnished under the
contract.
aa. To ensure that security requirements for contractors are adhered to in

accordance with ACS Directive OM: 5-101, Contractor Employee Personnel
Security Screenings.
bb. To inform the CO in writing of any work being performed by the contractor that 1s
not authorized in the scope of the contract.
5, LIMITATIONS: You are prohibited form taking any action with respect lo the following:
a. To authorize commencement of work at the beginning of a contract or in

circumstances involving an increase of work, unless and until the Contmct1ng
Officer has authorized the Contractor to proceed to work.
b. To encourage or approve, by word, actions, or omissions, any action by a

contractor, which would require the Contracting Officer's approval. but has not
received approval from the Contracting Officer.
c. To award, agree to, or sign any contract (including delivery and purchase orders)
or modification thereto, or in any direct or indirect way to obligate the payment of
money by the Government.
d. To give instructions or to make any form of agreement which affects the unit
price, total contract price, quantity, quality, delivery schedule, or scope of work.
Only the Contracting Officer can provide instructions and agreements of this
type.
6. The COR may designate an assistant lo act as his/her representative as a result of

his/her absence; however, prior approval of such designation must be received in writing
from the Contracting Officer.
7 Written communications with the Contractor and documents shall be signed as

"Contractmg Officer's Representative"' (COR). with a copy furnished to the Contracliny
Officer.
Page 4 of 5
• •
COR Design:1tion Letter

Co11tract No. ED-FSA-09-0-0014
TIVAS - PHEAA
3 By s1gn1ng below you cer-:ify lt:ai you lla·ve read, understc1nU and agree (Q these
,r:stn1ctions You are also requ.rcd to acknowledoc receipt of :I·1IsCcs,gncilicn (or
ten:11nation) in the space_prnrRJei:rtliJlo'M--8eturn the 'Jriginal ac~nowledgen~ent w1\l""'.ri_:
lt:,n
(b)(6)
1
{ 101 days !o the Contrac(111\J Officer for rctcnt1 1n lne contrc>cl rile. A dupfrcale copy 1s
p,ovi.:led for your r, 1 ords to be maint::iined in'/ ur COR files.
Michael Wh ler
Contrac:ing OWc1;r
Federal Student Aid
Phone (202) 377-3450
Date:
rb)~
R::CEIPT OF THIS DESIGNATION IS HEREBY AC.~NOWLEDGED. I HAVE READ AND FULLY
U.'WERSTArn THE AUTHORITY AND Lll•,11NTATIONSCONTAINED THEREIN:
COR: l\waku Appiai?" ';fr'

FSA Business Operations Group
Telephone No (202) 377-3723
Date: 5 /,,i,· /1c
f_Q_B._CONTRACTOR USE: RECEIPT OF THE CONTRACTOR'S COPY OF THIS

DESIGr~ATION IS HEREBY ACKNOWLEDGED. I HAVE READ AND FULLY Ut-JDEl~STAND
THE Al ITHORIIY AND I l(vtJJATIQN$ OF THE COR.
(b)(6) I
l
L. =~~==~-___J._·
CONTRACTOR SIGNATURE
-~-/¼i[k., Printed Name
.tJ.
__
~-cle.>a --
Title:
PHE/\A
D2te:
Page 5 oi 5
Federal Acquisition Certification

for
Contracting Officer Technical Representative
-
Kwaku Appiah •
Has met the required 40 hours of initial training
Date of Issuance: November 18, 2008
FEDERAL
,
ACQUISITION
INSTITUTE b)(6)
•
Karen Pica
Director, Federal Acquisition Institute Patrick Bradfield
FSA-39
Head of Contract1nq Act1v· uthorized Aqent for
•
• FSA090014-008
·1PAGjEOF PAG;s
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1. CONTRACT 'D CODE:
13, 4 REQUISmON1PUflCHASE REG, NO ,.PROJCCT NO. 111appbcblel

' AMF.NOMENT1MOOIFICA T10N NO.
008
fFFECl IVE DATE
MAY 26. 2010 EDOFSA-10-000538
6. ISSUED BY
COCE FSA-FS2
'SeeAOMINISTERW
Block 6
BY (II ollie, tl,dn Item 6! CODE

Washington DC 20202
~
8. NAME ANO ADDRESS Of CQrJTRACIOR rNo., ,ueet, cou11W, $We aNJ 7.IP Code) 9A AMENOMUH Of SOLICIATION NO,
1200 NORTH SEVENTH STREET Cage Code- 41UK7
96. DA TEO ISEE ITEM 11!
10A. MODIFICATION Of C.ONTRACT/ORDER NO.

ED·FSA-09-0-0014
K
-os OAlED ($(E ,T~M 13)
CODE 00030774 IFACILITY CODE JUN 17, 2009

0 The ebovo numl>ered aolicotation i, amended a, set tonn in l!om 14. Tho hour and date spoc,fa,d for re<olpl of Offors O io e.rondod, 0 is no! e,tefl<iod.
Ofle,, onus\ acknowledge roce;p! of Uus oowodmenl prior to 1™>hoor and date specified ,n !M ,.c,l1cnoi;,,nor o, amended, by OM of !110folh>Wlng n1<thods:
la)By complehr.g itom, 8 and \5, and relum,og cop,os ol tho amendment; lbl By ackncwlodging ,oco,pt of th,s amendment oo each copy of the ofter submitted;
0 , lei By soparato lottar or telegram wNch 1ncludos a referonco to tho ,olidtalion and amendmon! numbou, FAllURE Of YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THI.'
PLACE DESIGtlATl.'D FOR THE RECEIPT OF OFFHIS PRIOR TO THE HOUR ANO OAT( Sf>ECIFlcD MAY RESULT IN REJECTION OF YOUR OFFER. If by sift'-"' of thos amendmon!
•iour Josoto ro chango an oHer already ,ub-n,!t6d, •<><:hchange mo·1 Lo modo by tologram or letter, pro,oded ""ch tologrnm or lotter makes ,elerenco lo Pl<!sol1c,ta1<00and tf-,s
amendmo'1!, .,nd is ,oce,ved prior •o the opeC,ng hou, and doto SP<'C•l.,d.
Modification Amount: $25,553,183.00

See Schedule Modification Obligated Amount· $25,553, 183 00
13 THIS ITEM ONLY APPLIES TO MODIFICATIONOF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDERNO. AS DESCRIBED IN ITEM 14.
CHE'CK ONE A, THIS CHANG£ UH om ,s IS~IJ~D PURSUANT TO, ISpoc,ty outh~rotyl THE CHANGES ser .ORTH IN IHM 14 ARE MADE IN THE CONTRACT ORDER
NO ltl ITEM JOA,
B. THE ABOVE NUMBERW COrHRACT.'ORDl'R IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes"' pay,ng otfico,
apprnp.,ation doto. etc J SET FORTH 11-lITEM 14, PURSUANT TO THE AUTHORlli' OF FAR 43.1031bJ.
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED ;fl/TO PURSUANT TO AUTHORITY OF:
X a mutual agreement of parties.
E. IMPORTANT: Contractor D is not, [;] Is required to sign this document and return copies to the issuing office.
14 DlcSCRIPTION OF AMENDMENT/MODIFICATION (Organoted by UCF section ~eadlngs. ,ncrud,ng soicolationioonlracl subject maller where (eas,ble)
The purpose of this modification is to execute Task Order 004 for the servicing of borrowers.
Funding in the amount of $25,553,183 is added to support this effort. The current no!-to-exceed limit Is increased by $25,553, 183 from
$11,166 395.10 to $36,719,578.10.
This Task Order shall be effective immediately following the conclusion of Task Order 001 Unique invoices shall be submitted for this Task
Order, separate from invoices submatted for other task orders awarded under this base contract.
All other temis and conditions remain unchanged.
15A. NAME AND TITlE Of $1GtlER I Typo or print) 16A, NAME ANO TITLE o; C TRACT:NG OFF:C~,ITy~ Q< prn1tl
Mike Whisler )
Matthew D. Sessa, Program Director mike.whislerlRled..,ov'
I
,S,griaMe ot Coc.1ract1c.g •earl
N~N ?540-01 152-60?0 STANDARD FORM 30 ,APv.10-SJI

1'<0,nJuo """'"" unu,ao,o r,e,cr,b8d bv GSA fAA 148 CFA: 5) .143
OBTAINED
• •
• BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
---- -ce-,--s_c_H_E_o_u_L_E_C_oca_,_i:-~
---so-,-,-u-es-,..s-,-,-
-:-,:-,n-~-"'-"-~-
_""""-"'-"-,
' I
-,-,,-,-.--~--

I I
0202A2010.B.2010.ENB00000.6CA.2572A.AB5.000.0000
000000
Cost Applied. $25,553.183.00
(New line Item)

0004 Title IV Student Financial Aid Servicing 1 QO SE 25,553,183.00 25,553, 183.00
PAGE 2 OF 2

1
CONTRACT ID CODE [ PAGE oj PAG;s
1
' AMENDMENT MODIFICATION NO
009
13-
EFFECTIVE DA TE
JUL 27, 2010
'· REQUISITION/PURCHASE REO NO.
I;PROJECT NO ill apphcblel
6. ISSUED BY 7. ADMINISTERED BY Ill other than Item 61

CODE FSA-FS2 CODE
United States Department of Education See Block 6
Washington DC 20202
- rxr
8. NAME AND ADDRESS OF CONTRACTOR IIJo.. streH. county, State and ZIP Code) 9A. AMENDMENT OF SOLICIA TION NO.
HIGHER EDUCATION ASSISTANCE AGENCY. PA DUNS: 007368103
1200 NORTH SEVENTH STREET Cage Code: 41 UK?
98. DA TED ISEE ITEM 111
10A. MODIFICATION OF CONTRACT,OROER NO

ED-FSA-09-D-0014
X
1QB DATED(SEE ITEM 13)

D The above nun1bered sohcnat,on os amended as set forth u1 Item 14. The hour and date spec,hed for receipt of Offers D ,s extended, D Is not extended
Otfeos must acknowledge rece,pt of 1h1samendment prior to the hour and d,,to spec,hed ,n tl1e sohcnat,on or as amended, by one of the following methods,
lalBy complet,ng items 8 and 15, and ret<irrnng copies of tl1e amendment: ibl By acknowledging receipt of this amendment on each copy of the offer sobm,tted;
or lei By separate lel!er or telegram which onclodes a reference to the solic1tat,on and amendment nwnbe;s_ FAILURE OF YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THE
PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR ANO DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER If by vortuo of this amendment
you, desire to change an olfor already subm,tled, such change may be made by telegram or letter, prov,dad each telegram or letler makes ,eference to the sol1c1tatoonand this
amendment, and os rece,ved prior to the opening l10ur and date spec,l,ed.
12 ACCOU~TING ANO APPROPIATIONDATA (lfreq""MI

Modification Amount· $0.00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14
CHECK ONE A THIS CHANGE ORDER IS ISSUED PURSUANT TO iSpec,fy authority I THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER
NO. IN ITEM 10A
8. THE ABOVE NUMBERED CONTRACT.'ORDER IS MODIFIED TO REFLECT THE AOMINISTRA TIVE CHANGES !such~• changes ,n pay,ng office.
appropriatI001 date. etc I SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103IbJ.
C. THIS SUPPLEMENT AL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:
X a mutual consent of parties.
D. OTHER {Specify type of mod1f,cat,on and authority)
E. IMPORTANT: Contractor D is not, 0 is required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Organ,zed by UCF sectoon headings, Includ,ng sohc,talion/contract subJecl ma lier where feasible /
The purpose of this modification is to add the following clause lo Section 8.2. "52.252-2 Clauses Incorporated By Reference (Feb 1998)" of the
contract:
(1) 52 204-10, Reporting Executive Compensation and First-Tier Subcontract Awards (Jul 2010)
Except .as prov,ded her~m. all terms and co11d1t1onsof the document referenced In Item 9A or 10A, as hereta!ore changed. remains uncl,anged and"' full fo,ce and effect,
15A NAME AND TITLE OF SIGNER !Type or print! 16A. NAME AND TITLE OF CONTRACTING OFFICER IType or prn1ti
Nicholas Chung
15B CONTRACTOR,OFFEROR
202-377-3635
l 116C DA TE SIGNED
JUL 27, 2010

!Signature of p~rson aut110nzed !o sign!
NSN 7540-01 152-8070 STANDARD FORM 30 IREV.10-83I

Piev,ous ed<1,ununusablP Presc11bed bv GSA FAR 148 CFRI 53 243
r AMENDMENT
'
OF SOLICIT ATION/MODJFICATION
AMENDMENT 1MOOIF,CAT10N NO.
010
•
13. EFFECTIVE DA TE
AUG 11, 2010
OF CONTRACT
'
l1
REOUISITIONIPURCHASE
•
CONTRACT II) CODE
f!EO NO,
FSA090014-010
I'
l o,)PA,,;s
j "AG
1
PROJECT NO 1,1,,ppl,ct,lel
6 ISSUED BY CODE FSA-FS2 ADMINISTERED

United States Department of Education 'See Block 6 BY llf other !hao Item 61
CODE

Washington DC 20202
8. NAME AND ADDRESS OF CONTRACTOR !No., street. county, State and ZIP Code)
HIGHER EDUCATION ASSISTANCE AGENCY, PA ___0_)_
9A. AMENDMENT OF SOLICIA TION NO
DUNS: 007368103
1200 NORTH SEVENTH STREET Cage Code. 41 UK7
HARRISBURG PA 171021419 98 DA TED ISEE ITEM 111
10A. MODIFICATION OF CONTRACTiORDER NO.

ED-FSA-09-D-0014
K
108 DATEDiSEE ITtM 13)
CODE 0003077 4 ]FACILITY CODE JUN 17. 2009
11. THIS ITEM ONLY APPLIES TO AMENDMENTS
~~--------------- OF SOLICITATIONS
□ The above numbered sohc,tat,on ,s amended as set forth ,n Item 14, The hour and date spec,hed tor
rece,pt o/ Offers D
,s extended, 0
,s not extended,
Oilers must ,,cknowledge ,ece,pt of thos amendmer>t proor to the hour and date specified m the sohc,1ation
or as amended, by one of the followrng methods,
talBY cumplehng items 8 and 15 and returrnng cop,es of the amendment: (bl By acknowledging <ete,pt ol this amendment on each copy of tho offer
subm,ued;
or lei By separate lener o, telegram wh•ch mcludes a reference to the solic,tat,on and amendment numl1ers. FAILURE
OF YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THE
PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY
RESULT IN REJECTION OF YOUR OFFER. II by v,nue o! this amendment
your desi,e to changa ,1n offer already subm,ned, such change may l>e made by telegram or letter, provided
each 1elegram or letter makes referenca to the solicotat,on and thos
amendm,•nt. and rn received prior to the openong hour and <late spec,fied.
12 ACCOUNT•NGANO APPROPIATION DATA (If roqu1red1

Modification Amount: $0 00
13. THIS ffEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS.
IT MODIF!ES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14
CHECK ONE A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: ISpec,fy authorotyl THE CHANGES SET FORTH IN
ITEM 14 ARE MADE IN THE CONTRACT ORDER
NO IN ITEM JOA.
X B. THE A80VE NUMBERED CONTRACf10RDEA IS MODIFIED TO REFLECT THE ADMlrJISTRA TIVE CHANGES
appropuatIon date, etc.I SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAA 43. 103ibl,
(such as changes ,n paymg oU,ce.
C [HIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:
D. OTHER ISpec,fy type of mod,fica1ion and authority)
E. IMPORTANT. Contractor O is not, @ Is required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Orgarnzed by UCF section headings, onclud1ng solrcrtalion/contrnct subject mailer where feasible I
The purpose of this modification is to replace the Contracting Officer's Representative (COR) designated in
Section 8.13.M of the contract as
follows, effective immediately:
Mr. Michael J_ Murray

Federal Student Aid
830 First Street, NE Suite 61J1
Email' m1chael.jmurray@ed.gov
Phone. (202) 377-3273
A copy of Mr. Murray's COR designation letter and COTR certification letter are attached herein. All other terms
and conditions remain
unchanged.
Exco p1 as prov,dDd herem all term" and condit,on~ of the document referenced ,n l!em SA or 10A as heretofore ~hanged rpmains unchanged and ,n full force and e'1ect
15A. NAME AND TITLE OF SIGNER IT vpe o, prmtl 16A. NAME ANO TITLE OF CONTRACTING
MatthE1\I)' D. SAsa, P.i:,9gram Director

Mike Whisler
mike whisler@ed.qov
f\ OFf,~r print)
15C ;:)ATE SIGNE;) · IOC CATE SIGNED

fbl(6)
I 8/20/2010
l(b)(6)
I
IS,grwLlrn of person authOrozed 10 sogn> f~•gnature o, ~ontrael,ng Otf,cefl
AUG 11, 2010
NSN -~40-01 152-8070
STANDARD FORM 30 ,REV 10-831
Prev,nus erl,t>on unus~bl~
P,eswbed THE FREEDOM
by GSA OF5-1
FAA 148 CFRI INFORMATION
243 ACT
r
• •
MEMORANDUM
U.S. DEPARTMENT OF EDUCATION
FEDERAL STUDENT AID ACQUISITIONS
TO: Michael J. Murray

FROM: Michael VVhisler,Contracting Officer
DATE: August 10, 20 IO
SUBJECT: DESIGNATION OF CONTRACTING OFFICER'S REPRESENTATIVE FOR THE
PROCUREMENT OF TITLE IV STUDENT FINANCIAL AID
MANAGEMENT/SERVICING, UNDER THE TITLE IV ADDITIONAL SERVICERS
(TIVAS) PROGRAM.
Under the provision ofED-FSA-09-D-0014, dated: June l 7, 2009, with Pennsylvania Higher Education
Assistance Agency (PHEAA):
1. This is to certify that Michael J. Murray of Federal Student Aid Business Operations is hereby
designated as the Contracting Officer's Representative (COR) for the above referenced contract.
2. This designation will rernam in effect from contract award through contract termination, unless
sooner terminated in writing by the Contracting Officer or successor, or by reason of your
reassignment, resignation or termination.
3. The Contracting Officer is to be notified immediately if you receive notice of reassignment, or
when you will be absent for an extended period of time or otherwise be unable to fulfill the
responsibilities of this position. In your absence, notification is to be given by your immediatl:
superior. You are required to maintain current COR certification in accordance with program
requirements. Details may be found on the OCFO/CPO website on ConncctED.
4. The Contracting Officer (CO) is the exclusive agent of the Government with authority to enter
into and administer contracts. Thus, the CO has the responsibility to see that all requirements of
law and regulation are follmved. However, as the CO's representative you are delegated the
authority to monitor the technical effort being performed under the contract. You should
familiarize yourself with the requirements of the contract, and communicate with the Contractor
as necessary to ensure the contractor is making satisfactory progress in perfonnance of the
contract. Other than the CO, you are the only Government employee who may direct the flow of
technical matters between the Govemm~nt and the Contractor.
5. A contract is a legally enforceable agreement that contains the rights and remedies of the parties.
If the Contractor deviates from the terms of the contract, it 1s a matter between the Government
(represented by the CO) and the Contractor. You must keep the CO fully informed so that legally
effective solutions can be applied to problems as they develop. Your suggestions to the
Contractor may be construed as instructions and lead to claims for additional compensation or to
a release of the Contractor from its obligations under the contract. Suggestions sometnncs work
out, but often lead to misunderstandings. Therefore, while you can and must make technical
decisions, do not take any contract administration actions unless they are clearly authorized by
this appointment.
6. AUTHORITY AND DUTIES: You are hereby authorized by this designation to take any and all
action with respect to the following which could lawfully be taken by the Contracting Officer,
except any action specifically prohibited by the terms of the subject contract and paragraph 7,
"LIMITATIONS, of this designation.
a. To monitor and to assure that the Contractor performs the technical requirement of the
contract, to mclude inspection and testmg of deliverables and evaluation of reports in
• •
accordance with the contract tem1s, conditwns, specification and drawings. Ensure any
inspections performed arc necessary to assure compliance with all contract technical
requirements and require the Contractor to correct any deficiencies. Upon technical
acceptance of completed work for Federal Student Aid complete a record of mspcction and
acceptance on the "Material Inspection and Receiving Report", or other applicable fonn.
When reports /forms arc prepared ensure they are forwarded to the Contracting Officer.
b. As the individual named in the contract as the COR, you are the sole person (other than the
CO), after appropriate coordination with the PM, with the authority to communicate techmcal
direction or to recommend final acceptance or rejection to the CO.
c. To prepare a COR Work plan and establish and maintain appropriate record-keeping files.
d. To review, evaluate and comment on any aspects of the contract and its performance to
include problem areas, proposals, and technical issues, and to make written recommendations
to the Contracting Officer.
c. To communicate and coordinate directly with the Contractor to the extent necessary to carry
out your duties as COR except as prohibited in paragraph 7, "LIMITATIONS" of this
designation.
f. To attend post-award, negotiation, and other conferences. Assist and participate in the post
a\Vard orientation.
g. To coordinate site entry for Contractor/Government personnel as appropriate.
h. When site visits arc conducted, compare actual accomplishments with scheduled and report
performance. Be alert to changes in technical perfonnance that may affect the financial
status, personnel, or other elements of performance.
1. To ensure that Government Furnished Property (GFP), if provided in the contract (including
software), is available when required and proper documentation is obtained when such
property is transferred. Review the contractor's property control system and sofhvare
configuration management to ensure compliance with Government property clauses and
recommend to the CO either approval or disapproval of the system.
1- To ensure accountability ofGFP and Contractor Acquired Property (CAP) is established
upon receipt of the property and an auditable record of ownership is maintained (Leased
Property must be included). Ensure that all Government property, whether government
furnished, contractor acquired, leased or contractor fabricated is properly labeled and
identified and that the department asset management database is updated.
k. To monitor the acquisition, control, and disposition of Government Property by Government
personnel and by the contractor. Assess contractor for any loss, damage, or destruction of
property. To verify maintenance activities are performed.
I. To ensure the contractor, in accordance with FAR 45.508, conducts accurate and timely
periodic inventories according to an'established schedule approved by the Property
Administrator. Have the contractor submit electronic reports indicating the results of the
inventories performed. Document upon discovery any discrepancies, or upon identification of
misuse or loss, and resolve all discrepancies.
m. To provide appropriate notification to the Contracting Officer in any instance when his/her
immediate or expeditious decision is required. Immediately report contractor performance
problems to the CO/CS.
n. To prepare a \\-Titten evaluation of the contractor's performance within 45 days after
completion of any contract in accordance with the guidelines provided at the OC FO
Pmat!t1tl'.\ that II 'ork Wt..'bsiteon conncctED.
o. To provide to the Contracting Officer sufficient evidence of a breach, and suggestion for an
appropriate contract remedy, if a breach of contract is identified and assist in evaluating
contractor response.
r
• •
p. To assist the CO in detcnnining whether to terminate a contract.

q. To review progress and financial reports, invoices, vouchers, and recommend approval or
disapproval by the CO. To enter receipts into the Contract and Purchasing Support System
(CPSS) after review of invoices/vouchers. In cost --reimbursement contracts exceeding
$100,000 estimated value, verify conformance with the clause "Payment for Overtime
Premiums". Also recommend approval and disapproval of overtime in Labor-Hour or Time-
and-Material contracts. Review and make timely recommendations to the CO as to the
approval, disapproval, or other action to take concerning a contractor's submission of(or
failure to submit) payment requests, deliverables, interim or final progress and financial
reports, or any other requirements of the contract. Maintain a record/summary of payments to
date to ensure that short-term progress is viewed as part of the \vhole to help monitor
payment expenditures against total obligations.
r. To maintain all necessary records to document and describe the perfonnancc of your duties
as COR, and to distribute such records as applicable. You arc required to submit quarterly
and annual written perfonnance evaluations to the Contracting Officer concerning the
Contractor's progress and performance of the work or items delivered. This report will
include but is not limited to providing monitoring information, advice, and requests for
formal administrative action to the CO in a timely manner. If your designation is terminated
for any reason before completion of the contract, you will tum over your records to the
successor COR or obtain disposition instructions from the Contracting Officer.
s. To provide advice and assistance to the Contracting Officer in other areas of contract
administration which are not specifically covered in this designation. Keep the CO informed
of all communications with the contractor m order to prevent possible misunderstandings or
1
situations that could become the bas is for future claims against the Government. Only the
requirements written in the contract can be asked of the contractor. If additional requirements
seem necessary, discuss them with the CO and PM, but do not try to enforce them unless the
CO modifies the contract in writing.
t. To review and recommend in writing contract modification requests or changes to the SOW
and period of performance necessary to accomplish the objective of the contract. Prepare a
technical evaluation to support a determmation that the change is not outside the scope of the
contract. For contractor initiated changes, direct the contractor to submit a written descnption
that includes the effect of the changes on the contract terms and conditions. Review the
submission and send it to the CO with your recommendation.
u. To recommend, in writing, to the CO whether an option should be exercised under the
contract (given a contract awarded with options and an option clause). Submit market
research data to the CO to support the recommendation to exercise the option.
v. To submit procurement request(s) for additional services/tasks.
w. To assist the CO, if asked, in administering Stop Work Orders.
x. To notify the CO about a delay in the delivery or performance schedule under the contract.
y. To assist the CO in analyzing a claim, recommend a settlement position, and participate in
the resolution process.
z. To advise the CO, at the completion of the contract, as to the receipt of all items, services and
reports required under the contract, and the compliance with all contract provisions. Also,
recommend a disposition of any Government Furnished/Contractor Acquired property in the
possession of the contractor, and verify the usage of any Government-owned consumable
furnished under the contract.
aa. To ensure that security requirements for contractors arc adhered to in accordance \Vith ACS
Directive OM: 5-IOI, Contractor Employee Personnel Security Screenings.
3
• •
bb. To inform the CO in writing of any work being performed by the contractor that is not
authonzed in the scope of the contr~ct.
7. LIMITATIONS: You arc prohibited from taking any action with respect to the following:
a. To authorize commencement of work at the beginning of a contract, or in circumstances
involving an increase of work, unless and until the Contracting Officer has authorized the
Contractor to proceed to work.
b. To encourage or approve, by word, act10ns, or omissions, any action by a contractor which
\Vould require the Contracting Officer's approval, but has not received approval from the
Contracting Officer.
c. To award, agree to, or sign any contract (including delivery and purchase orders) or
modification thereto, or in any direct or indirect way to obligate the payment of money by the
Government.
d. To give instructions or to make any fonn of agreement which affects the unit price, total
contract price, quantity, quality, delivery schedule, or scope of work. Only the Contracting
Officer can provide instructions and agreements of this type.
8. The COR may designate an assistant to act as hisiher representative as a result of his/her
absence; however, prior approval of such designation must be received in writing from the
9. Written communications with the Contractor and any other contract related documents shall be
signed as "Contracting Officer's Representative" (COR), with a copy furnished to the
Contracting Otlicer.
I 0. By signing below you certify that you have read, understand and agree to these instrnctions. You
arc also required to acknowledge receipt of this designation (or termination) m the space
provided below. Return the onginal ackilowledgement within ten (10) days to the Contracting
Officer for retention in the contra le. A duplicate copy is provided for your records to be
maintained in your C R files.
b)(6)
CONTRAC ING OFFICER DATE

'
RECEIPT OF THIS DESIGNATION IS HEREBY ACKNOWLEDGED. I HA VE READ AND FULLY
UNDERSTAND THE A AND LIMITATIONS CONTAINED THEREIN:
(b)(6)
f:11:,<0 O
COR DATE
TELEPHONE NUMBER
4
• •
FOR CONTRACTOR USE: RECEIPT OF THE COl'<TRACTOR'S COPY OF THIS DESIGNATION

IS HEREBY ACKNOWLEDGED. I HA VE READ AND FULLY UNDERSTAND THE AUTHORITY
AND LIMITATIONS OF THE COR.
CONTRACTOR SIGNATURE DATE
TITLE
ThJ~Dm:lce
~)p:Jr&f\J,cin Bt:M
COM
3
THIS DESIGNATION IS HEREBY TERMINATED EFFECTIVE
WITHOUT PREJUDICE TO ANY ACTIONS TAKEN PURSUANT THERETO BY THE
DESIGNATED COR.
CONTRACTING OFFICER SIGNATURE
RECEIPT OF TERMINATION AS COR IS HEREBY ACKNOWLEDGED:
COR SIGNATURE DATE
Cc
Contractor
Conlruct File
(Controlling Program Management Qffice)
5
Federal AcquisitionCertification
for
Contracting Officer Technical Representative
Michael J. Murray •
Has met the required 40 hours of initial training
Date of Issuance: November 24, 2008
@ FEDERAL
ACQUISITION
INSTITUTE 8
§
•
j ~1 I\ /1.~ ZOOi
Karen Pica
FSA-54
Director, Federal Acquisition Institute
Head of Contracting ActivitUuthorized Agent for
AMENDMENT
2. AIENllDfTIMOOIFICAlDIII
OF SOLICITATION/MOOIFICATION
N,'.>.
•
FSA090014-0ll
13"EFffCTMOA.TE
OF CONTRACT
◄- ~ AEQ. NO.
\1·COlmlACTOCODl • 15-
P'AlJECTNO. !11'
l~'i'~
..,,«;d,ktl
...._.
011 NOV22,2010 EOOFSA-11-000100
coo,; FSA-FS2 fN Ill .,._ _, Imm 81
' Uniled StalesDepartnwtt <AEdocetion 1. AOMIMS"l'ERED coo,
Federal Slla,nt~ ~ Gn:,up

830 Ffnt St NE· Sulll 91F3
-DC20202
8. N-"M2: N#lJN.IOlel5 Of COW1llACTOR

HIGHER EDUCATION ASSISTANCE AGENCY. PA
HARRiSBURGPA 17102:1-419
!No..,-..,_,,,,_
91:MZ- "l'Jl>Codlo!
DUNS: 007366103
Cage Cooa: 41UK7
- {XI 9't.. AMENlMElff
!IB 0,t,TlDfS&ITtM
OF SOUOAllON JIO.
11!
lOA. MODIFICA~ OF CCHIRACTKlRDER NO.

ED-FSA-00-0-0014
I
1111'1.-'fRl!WEffEJllq
CODE0CKl3077◄ IFN::LlfY COOE JUN 17, 2009
11. THIS ITEM ONLY APPLIES TOAMEHDll£NTS OF SOLICITATIONS
□ 1""_ ........... _._.. ........... __ ....,ln
__ l4. TI.a-...t.i..opd;w
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IM90&d:laltan .-d wk. :l e • ........._ FAIJJRE Ofl'Ol,II.ACICMOVlol..B:XT TO 8E R£CBVEOAT llE
.,_..,..,tt-...,..,,.,....,.__,_
......,.,........,.bo,_..bJ'
..........................
l'\JIICI: Dell0'44TEO FOIi:1HE RflCA'f Of Off'9IS 1'11011
_,.-.- ........................
tO THEHOURNG MTE SPE.OAEOMAYFIESULT
l't RUECtl0N OF 'l'OUI. Off8l.
11.., ,._ <,I ._ • ••odo•••t
n_,;ng--.....,~-
--
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......._tt. ...ti......._ pr1o<1o
12. ACOOIMTN)IMO lli"l'l"ICAIITION Do\TA(f ....-1 Modification Amoont $11,000,000.00
Mocification.ObiglladAmount $11,000,000.00
13. THIS ITEMONl.Y APPLIESTO MOOIACATION
Of CONTRACTSK>RDERS.
IT MODIAES 1l1E COM'RACT/OROER
NO AS DESCRtsEO IN ITEM 14
OECk ONE A. TMIS0tAMJE OIWJEiJI
IS ISl9lEO "llASl.WIIT TO: __,.~THE OUiNGBSEt FORf}j ffll !TEN 14 AAi..MMX IN THECOhTAACT OfO£R
NO... rT91110A,
8. Utt AlilO\IE....._W awnt.!Cf!OID:R ISIAlOFIHI TO FFR..l:CfM AOria,ISTRATM OWo10F.S leuch • ~;,, o1-._
J11111it,g
....
, ... @ ._., IICJ li£T fORlN 1MITTM l-4., f'UASUNiT TO~ AUn«)IWly Of FAA "3. 1Q3ti.
C. THl'SSUf'R.S,,la,fTAL A.GFUMl:IIT IS ENnRfD INTO PUISUNfT TO AI.JT!CHTY Of:
X By Mutual Agree(neri of lhe P81'tiee
E. IMPORTANT: Contract°' 0 Is ooc, G}IS r~ 1 copie& to the issuing offiee.

UI. OESCAPnOftOF ~ffJN~to,
The PlJfl)l)58 oftlia rt◄ •llcakin ISto add b'ldlng for
wa-,...,..,.
UCf
to sign this document and return
openmons..
.....,llaM::GI_
.....,_...,..,.._i..:t...)
l,ll:luclloQ
Al other terms and condillon& rnmaln unchanged end in full effect
16"- NAMENC> TrnE OF &KHA f'f,p,o .- p,at l&A. MAMENO TlTl.E OF COHTMCTlNG Offfl.1'R fl',i,e ..- ,md
Hatt.hew D. Sessa, Program Director BndeyBumoemer
202-3n-.3487
HIC. OAIT S!(;NUl
(b)(6)
I
o•
NSN 7540-0M62-807(1 ST AND ARD FOAM 30 IJ£\/. 1~
Pr......,.adloorl_ ~ i,,,, GSA FM 146 O""tl S3 2"3
I
,---~-
r·---;T-E-;-;;:- SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE $ AMOUNT $
(New Line Item)

0005 Accounting and Appropriation Data: 1.00 SE 11,000,000.00 11,000,000.00
0202A2011.B.2011.ENB00000.6CA.2572A.AB5.000.0000 000000
$11,000,000.00
PR NUMBER: EDOFSA-11-000100
DELIVERY DATE: 09/30/2011
SHIP TO:
Contracts & Acquisitions Mgt., Group C
US Dept of Education, 550 12th Street SW, 7th Floor
Washington DC 20202-4220
FOB · Destination
PAGE 2 OF 2
AMENDMENT OF SOLICITATION/MODIFICATION
OF CONTRACT
•
I I
•
! 1 Conlract ID Code j Paoe of PageCJ
I
2. AMENDMENT MOOIF!CATION NO.
j J_ EFFECTIVE DATE 4 ' REO. NO I 5. PROJEC
REQUISITION/PURCHASE
1 I II
T NO i1f ,1ppHcable)
013 MAR 14, 2011
6. ISSUED BY CODE
lmneo Slates Depar.menl o! E<Juta•k>o FSA-FS2 7 ADMINISTERED BY (If other lhan ,lern 6)
Fa<Je,al Slod~nl A;j/1>,MSlortSupp,ort o,cop
CODE
I S30 F~S! St NE , Suote 91F3 See Block 6
w~sti,ng!on DC W20:Z
Julia Jonu
8. NAME AND ADDRESS OF CONTRACTOR (NO.,

Slffl8t, Counfly, S(ate and ZIP Code)
PENNSYLVANIA HIGHER EDUCATION ASSISTANCE 9A AMENDMENT OF SOLICITATION NO.
1200 N 7TH ST
AGENCY DUNS: 007368103
Cage Code: 41UK7 -(X)
98. DATED (SEE ITEM 11)
JOA MODIFICATION QF CONTRACT/ORDER NO.

E~SA-09-0-0014
X
CODE 00030774 j FAGILITY CODE
JUN 17, 2009
11, THIS ITEM ONLY APPLIES TO AMENDMENTS
OF Sot/CITATIONS
0 Tha above numbered sollcit.atkln is amended a.s set
Offers must acknowledge receipt of this amendment
forth In ijem 14. The hour and data Sp@cifiedfor f8C81pl
prior !o the hour and data specified In the sollcit.allon
or offlm1 Is exlanded,D Dis
not a:dendad.
(a) By compleUng Iiams 8 and 15. and returning __ or as amended, by one of the following methods:
copies of amoodmanl; jb) By ar:knowledglng racelpl
or (c) By separate letter or telegram which lncfudss ofthls amendment on each copy of the offer submitte
a reference lo Iha sollcilatlon and amendment numbera d;
F1ECEIVED AT THE PLACE DESIGNATED FOR THE . FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIPT OR OFFERS PRIOR TO THE HOUR ANO
YOUR OFFER. ti by virtue of this amoodment your DATE SPECIFIED MAY RESULT IN REJECTION
desi,e to ctiange an offer already submitted. such change OF
1ei..nram or letter makes reference to the solicit.allon may be made by 1elegram or letter, provided each
and this amendment and Is n:icaived -"-· to the onenlnn
12. ACCOUNTING ANO APPROPRIATION DATA (tfrequim hour ar>ddates ---/fled.
d)
Modification "mount: "'O ul
Sae Schedule
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF
CONTRACTS/ORDERS. IT MODIFIES THE CONTR
ACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A. THIS ORDER ID ISSUED PURSUANT TO· (Specify authority) THE CHANGES
ORDER NO IN ITEM 10A. SET FORTH IN ITEM i4 ARE MADE IN THE CONTR
ACT
B THE ABOVE NUMBERED CONT,,,. CT/ORDER IS

X offic;a. appropriation dale, etc) SET FORTH IN ITEM
MOD IFJED TO REFLECT THE ADMINISTRATIVE
CHANGES (such as changes In paying
14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b
)
C THIS SUPPLEMENTAL AGREEMENT IS ENTERE
D INTO PURSUANT TO AUTHORITY OF:
0. OTHER {Specify type of modlficallon and authority)
.
E. IMPORTANT: Contractor I is not, 15<
is required to sign this document and return
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF copies to the Issuing office.
seclloo headill!IS, Including soUcit.allon/ooritracl subject '
matter where feas,llfe)
See Supplementary Page.
E,,,-• ~• ~- '-e"',
'i.
H !enno s<>dc;ooo;no,,. of lhe <locumen! refe,-flflC
f!d
In Hom ~A o,- 10A, 35 ~erolofon, ed._.,, u and;,, fulllo<a, a.-.:l@""ct.
rr1 d-H
15A NA:E AN~
l:,tA..
L,:;.~~._SIG<~.~) -~pao,•print)
I l) 1.'.:.J~..\..
~/~~ia';Ch~~Nv
02-377-3635
ITU:' OF wN rlV\CTING OFFICER (Type or pnnt)
nlcholasctlung@ed.gov
\0, l{L·,.i_c1:n t),1-:f re,ti;( i/rr,,1 -'-tree;,\
_158. CONTRACTO FfEROR
<'. /-· . 15C DATE SIGNED t6a: UNITEDSTAl}:_S OF AMERICA
16C. DATE SIGNED
'
[b)(6)
(Signature of person authortz0d lo sign)

I .
(b)(6)
~AR 16,2011
na re o 00
NSN 7540·01-152-8070
Prc\·rous Ed1t1onunusable
.
STANDARD FORM JO. (Rev, to-83)
PrescriMd by GSA FAR (48 CFR) 5J.243
• •
Supplementary Page
Description of Modification/Amendment:
The purposes of this modification are as follow:
1. Replace Michael J. Murray, Federal Student Aid

Contracting Officer's Representative (COR) designation
identified in Modification 0010 of the contract, effect
ive immediately with:
Tammy Connelly(Primary COR)

Federal Student Aid
UCP-62A4
Washington DC 20202
Email: tammy.connelly@ed.gov
Phone: (202) 377-3298
And
Veer Sain (Alternate COR)

Federal Student Aid
UCP-61CS
Washington DC 20202
Email: veer.sain@ed.gov
Phone: (202) 377-3277
A copy of Tammy Connelly and Veer Sain COR desig

nation letter and COTR certification letter are attach
herein. ed
•
2. Correct the current not-to-exceed limit identified
in Modificatlon 012 to read:
#The current not-to-exceed limit is increased by $11,2
50,000 from $47.719,578 to $58,969,578.10#
3. All other terms and conditions of this contract remai
n unchanged and in full force and effect
PAGE 2 or 2 ED·FSA-09-D-0014/013
• •
MEMORANDUM
U S DEPARTMENT OF EDUCATION
FEDERAL STUDENT AID
ACQUISITIONS
TO Tammy Connelly, Primary COR and

Veer Sain, Alternate COR
FROM Nicholas Chung, Contracting Officer
DATE March 8, 2011
SUBJECT DESIGN A T!ON OF CONTRACTrNG OFFICER'

S
REPRESENTATIVE
FOR
Procurement of Title IV Additional Servicers Progr

am (TlV AS)
Under the provision of Contract No. ED-FSA-09-D-0

0l4 dated. June l 7, 2009 with
Pennsylvania Higher EJucation Assistance Agency
(PHEAA).
l. This is to certify that Tammy Connelly and Veer Sain
are hereby designated as the
Contracting Officer's Representatives (CORs) for
the above referenced contract.
2. This designation will remain in effect from contra
ct award through contract tennination
unless sooner terminated m writing by the Contracting
Officer or successor, or by reason
of your reassignment, resib,'llation or termination.
J. The Contracting Officer is to be notified imme

diately if you receive notice of
reassignment, or when you will be absent for an exten
ded period of time or otherwise he
unable to fulfill the responsibilities of this position.
In your absence, notification is to be
given by your immediate superior. You are required
to maintam current COR
certification in accordance with program requiremen
ts. Details may be found on the
OCFO/CPO website on ConnectED.
-1. The Contracting Officer (CO) is the exclusive

agent of the Government with authority to
enter mto and administer contracts. Thus, the CO
has the responsibility lo see that all
requirements of law and regulation arc followed. Howe
ver, as the CO's representative
you are delegah:d the authority to monitor the techn
ical effort being perfonned under the
contract. You should familiarize yourself with the
requirements of the contract, and
commuuicatc with the Contractor as necessary to
ensure !he contractor is makmg
sal1sfactory progress m perfo1mancc of the contract.
Other than the CO, you are the only
• •
Government employee who may direct the flO\v of(ech

nical matters between the
Government and the Conlr,1ctur.
5. A contract is a legally enforceable agreement that

contains the rights and remedies of the
parties. If the Contractor deviates from the tcm1s of the
contract, it is a matter bernicen
the Government (represented by the CO) and the Contra
ctor. You must keep the CO fully
informed so that legally effective solutions can be applie
d to problems as they develop.
Your suggestions to the Contractor may be construed
as instructions and lead to claims
for additional compensation or to a release of the Contractor
from its obligalions under
the contract. Suggestions sometimes \VOrkout, but often
lead to misunderstandings.
Therefore. while you can and must make technical decisi
ons, do not take any contract
administration actions unless !hey are clearly authorized
by this appointment.
6. AUTHORITY AND DUTIES: You are hereby author
ized by this designation to take any
and all aclion with respect to the following which could
lawfully be taken by the
Contracting Officer, except any action specifically prohib
ited by the terms of lhe subject
contract and paragraph 7, "L.UvtlTATIONS, of this design
ation.
a. To monitor and to assure that the Contractor performs
the technical requirement
of the contract, to include inspection and testing of delive
rables and evalualton of
reports in accordance with the contract terms, conditions,
specification and
drawings. Ensure any inspections performed arc necessary
to assure compliance
with all conlrn.cl technical requirements and require the
Contractor to correct any
deficiencies. Upon technical acceptance of completed work
for Federal Student
Aid complete a record of inspection and acceptance on
the "Material Inspection
and Receiving Report", or olher applicable fonn. \1/hen
reports /forms are
prepared ensure they are fonvarded to the Contracting Office
r.
b. As the individual named in lhc contract as the COR,
you are the sole person (other
than the CO), after appropriate coordination with the PM,
\Vith the authority to
communicate technical direction or to recommend final
acceptance or rejection to
the CO.
c. To prepare a COR Work plan and establish and maint

ain appropriate record-
keeping files.
d. To review, evaluate and comment on any aspects of

the contract and its
performance to include problem areas, proposals, and techni
cal issues, and to
make written recommendations to the Contracting Office
r.
e. To communicate and coordinate directly with the Contr
actor to the extent
necessary to carry out your duties as COR except as prohib
ited in paragraph 7,
"LIMIT ATIO NS" of this designation.
f. To attend post-award, negotia11on. and other conferences.

Assist and participate in
the post aw•Jrd oiientation.
• •
g. To coordinate si!e entry for Contrac1or:Gm-emment

personnel ns appropnate.
Ii. When site visrts are conducted, compare actual accom
plishments with scheduled
and repo1t performance. Be alert to changes in technical
performance that may
affect the financial stutus, personnel, or other elements
ofperfom1ance.
1. To ensure that Government Furnished Property (GFP)
, if provided in the contract
(including software), is available when required and proper
documentation is
obtained \vhen such property is transfe1Ted. Review the
contractor's property
control system and software configuration management
to ensure compliance
with Government property clauses and recommend to
the CO either approval or
disapproval of the system.
J. To ensure accountability of GFP and Contractor Acqui

red Property (CA.P) is
established upon receipt of the property and an auditable
record of ovmcrship is
maintained (Leased Property must be included). Ensure
that all Government
property, whether government furnished, contractor acquir
ed, !eased or contractor
fabricated is properly labeled and identified and that the
department asset
management database is updated.
k. To monitor the acquisition, control, and disposition

of Government Property by
Government personnel and by the contractor. Assess contra
ctor for any toss,
damage, or destmction of property. To verify maintenance
acti\'ities are
perfom1cd.
I. To ensure the contractor, in accordance with FAR 45.508

, conducts accurate and
timely periodic inventories according to an established
sd1edulc approved by the
Property Administrator. Have the contractor submit electro
nic reports indicating
the results of the inventories perConned. Document upon
discovery any
discrepancies, or upon identification of misuse or loss,
and resolve all
discrepancies.
m. To provide appropriate notification lo the Contracting

Officer in any instance
when his/her immediate or expeditious decision is requir
ed. Immediately report
contractor perfonnance problems to the CO/CS,
n_ To prepare a written evaluation of the contractor's

perfonnance withm 45 days
alter completion of any contract in accordance with the
guidelines provided al the
OCFO Procedurt!s tltac JV,,rk website on connectED.
o. To provide to the Contracting Officer sufficient eviden

ce of a breach, and
suggestion for :m appropriate contract remedy, if a breach
of wntracl is identified
and assist in evaluating contractor response.
p. To assist the CO in determining whether to termin

ate a contract.
• •
q. To review progress and financial reports, invoices,

vouchers, and recommend
approval or disapproval by the CO. To enter receipts into
the Contract and
Purchasing Support System (CPSS) after n;view of mvo1c
cs/vouchers. In cost -
reimbursement contracts exceeding $100,000 estimated
value, venfy
confonnance with the clause "Payment for Overtime Premi
ums". Also
recommend approval and disapproval of overtime in Labor
-Hour or Time-and-
Material contracts. Review and make timely recommenda
tions to the CO as to the
npproval, dis;ipproval, or other action to take concerning
a contractor's
submission of(or failure to submit) pa}1nent requests,
deliverables, interim or
final progress and financial reports, or any other requir
ements of the contract.
Maintain a record/summary of payments to date to ensure
that short-tenn progress
is viewed as part of the whole to help monitor payment
expenditures against total
obligations.
r. To maintain all necessary records to document and descri

be the pcrfonnance of
your duties as COR, and to distribute such records as
applicable. You are required
to '>Ubmitquarterly and annual written performance evalua
tions to the Contracting
Officer concerning the Contractor's progress and perfon
nance of the work or
items delivered. This report will include but is not limited
to providing monitoring
information, advice, and requests for formal administrativ
e action to the CO in a
timely manner. If your designation is terminated for any
reason before completion
of the contract, you will tum over your records to the
successor COR or obtam
disposition instructions from the Contrncting Officer.
s. To provide advice and assistance to the Contracting Office

r in other areas of
contract administration which are not specifically covere
d in this designation.
Keep the CO informed of all communications with the
contractor in order to
prevent possible misunderstandings or situations that
could become the basis for
future claims against the (',ovemment. Only the requir
ements written in the
contract can be asked of the contractor. ff additional requir
ements seem
necessary, discuss them ,vith the CO and PM, but do
not try to enforce them
unless the CO modifies the contract in \Vriting.
I. To reHew and recommend in writing contract modification

requests or changes to
the SOW and period ofperfonnarn:e necessary to accom
plish the objective of the
contract. Prepare a technical evaluation to support a detenn
ination that the change
is not outside the scope of the contract. For contractor
initiated changes, d1rect the
contractor to submit .i wrilten dcscnption that includes
the effect of the changes
on the contract tenns and conditions. Review the submi
ssion and send it 10 the
CO with your recommendation.
u. To recommend, in writing, to the CO whether an option

should be exercised
under the contract (given a contract awarded with option
s and an option clause).
Submit market research data to the CO to suppo11 the
recommendation to exercise
the op!lon.
• •
\' To suhm1t procurement rcquest(s) for add1t1onal servic

es/tasks.
w To assist the CO, if asked, m admimsterrng Stop Work
Orders.
x. To notify t!1eCO about a dday in the delivery or perfon
nancc schedule undt:r the
contract.
y. To assis1 the CO in analy1:ing a claim, recommend

a settlement position, and
participate in the resolution process.
z. To advise the CO, at the completion of the contract,

as to the receipt of all items,
services and reports n:4uircd under the contract, and the
compliance with all
contract provisions. Also, recommend a disposition of
any Government
Furnished/Contractor Acquired propt!rty in the possession
of the contractor, and
verity the usage of any GoYernment-owned consumable
furnished under the
contract.
aa. To ensure that security requirements for contractors

are adhered to in accordance
with ACS Directive OM: 5-IOI, Contractor Employee
Personnel Security
Screenings.
bb To inform the CO in wriling of any work being perfor

med by the contractor that
is not authorized in the scope of the contract.
7. LIMITATIONS: You are prohibited from taking any

action with respect to the following:
a. To authom::e commencement of work at the beginn

ing of a contract, or in
circumstances involving an increase of work, unless and
until the Contracting
Officer has authorized the Contractor to proceed to work.
b. To encourage or approve, hy word, actions, or omissi

ons, any action by a
contractor which would require the Contracting Office
r's approval, but has not
received approval from the Contracting Officer.
c. To award, agree to, or sign any contract (including delive

ry and purchase orders)
or moJification thereto, or in any direct or indirect way
to obligate the payment of
money by the Government.
d. To give instructions or to make any fonn of agreem

ent which afftc>ctsthe unit
price, total contract price, quantily, quality. delivery schedu
le, or scope of work.
Only the Contracting Officer can provide instructions
and agreements ofth1s type.
8. The COR may designate .in assistant to act as his/he
r representative as a result ofhisiher
a!Jsencc; however. prior approval of such designation
must he received m writmg from
the Contracting Officer.
• •
9. Wnttcn commm11cat1011s,vi1h the Contractor and any other

contract related documi:nts
shall be signed as "Contracting Officer's Representative" (COR)
, with a copy furnished
to the Contracting Ot1icer.
JO.By signing below you certify that you have read, understand
and agree to these
instmctions. You arc also required to acknowledge receipt ofth1s
dcs1gnat1on (or
termination) in the space provided below. Return the origina
l acknowledgement within
ten ( I 0) days lo the Contracting Officer for retention in the contrac
t file. A duplicate copy
is provided for your records to be maintained in your COR
files.
RECEIPT OF THIS DESIGNATION IS HEREBY ACKNOWLE

DGED. I HA VE READ AND
FULLY UNDERSTAND THE AUTHORfTY AND LIMIT
ATIONS CONTAINED THEREIN,
COR \.'\
I DATE
ORGANIZATION
._.{)1..- 3 7~ 3.;z,.
TELEPHONE Nl:MBER
I
"b)(6)
COR DATE
ORGANIZAT[ON
TELEPHONE NUMBER
• •
FOR CONTRACTOR l /SE, RECEIPT OF THE CONTRACT

OR'S COPY OF THIS
DESIGNATION IS HEREBY ACKNOWLEDGED I HAVE
READ AND FULLY
GND AND LIMITATIONS OF THE COR
w~ 5·--
,_) <:J.-'11
CONTRACTOR SIGNATURE DATE
C , PANY 'S --
THIS DESIGNATION IS HEREBY TERMINATED EFFEC
TIVE
W[THOUT PREJUDICE TO ANY ACTIONS TAKEN PURS ~===~c-=-
UANT THER ETO BY THE
DESIGNATED COR.
CONTRACTING OFFICER SIGNATURE
RECEIPT OF TERMINATION AS COR IS HEREBY ACKN

OWLEDGED,
COR S!GNATL'RE DATE
Cc
Contractor
Contract File
(Contm/ling Program J1anagemcnt OJ]ice)
Federal Acqt1isition Certif
ication
for C<11,tractir1gOfficer Tecl1
nical Represe1,tative
• Tammy Connelly
Ha s met the requirements fo
r certification
Date of issuance: Novem
ber 20. 2009
- - -
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U.S. Department
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Federal Acquisition Certific
ation
for Co11tracting Officer Techn
ical Represe11tative
• Veer Sain
Has met the requirements
for certification
Date of issuance: October
25, 2010
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:4~JFAI 1 _-~i\ U.S. Department

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of Education
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0c•'1C, r i:,,r,,.':r.rMO g
f"'e'I)_ \DP!J. C PM_ e
n ,,,, t·Js. f',.1~r201~v:1u,s·t Pat,,ck 8rad'f•,:,ld - ·------ ------
•~n 'nJ! 1,.t~ >SA? 1J
H,:,ad e,t th" t::ontr;,;t_,n~
.'. ,, i., F"d"•~t $',ll'"'. t".
D<:>palcr,ient~f [d1,cat,~~
0
A1,J
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT i 1

colltractiocode i__Page~f Page~ _J.,
i 1 3
2. AMENOMENT MODIFICATION NO 3 EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO 5 PROJECT NO {if applicable)
014 j APR 22, 2011 EDOFSA·11-000421
'61-fsurn BY CODE FSA-FS2 7 ADMINISTERED BY tlf other than ,tern 6)
i Un,lecl S1~tes Oepartrne111 or EoucalKm CODE
F~deral Sluden! ,\1diM1ss,on
Supp0<1 Group See Block 6
BJO Forsl$1 NE S'-'1e 97F3 I
wasri,ngton DC 202C2 '
Julia Jore• '
' 8. NAME AND ADDRESS OF CONTRACTOR (NO., Street. Country, Slate and ZIP Code) I
PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY DUNS· 007368103 I (X) 9A AMENDMENT OF SOLICITATION NO.
I
1200 N 7TH ST
Cage Code: 41UK7
i
I 98 DATED iSEE ITEM 11)
'r
I
i i
EO-FSfl-v9-0-0014
I
X I
10B. DATED {SEE ITEM 13)
CODE 00030774 : FACILITY CODE
JUN 17. 2009
I
0 The above numbered sol1citatIon Is amended as sel forth 111item 14. The hour and date specified for receipt of
offers D Is extended. Dis not ex\ended.
Offers must acknowledge receipt of this amendment prior lo the hour and date specified 111 the solici1atIon or as amended, by one of the following methods:
I (a) BY completing I1ems 8 and 15, and returning ___ copies of amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;
I or (c) By separate teller or telegram which indudes a reference lo 1he solicitation and amendment numbers
FAILURE OF YOUR ACKNOWLEDGMENT TO BE
I RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND
DATE SPECIFIED MAY RESULT IN REJECTION OF
; YOUR OFFER. If by virtue of \h,s amendment your desire to change an offer already submitted, such change
may be made by telegram or le tier, provided each
I tel=ram orletter makes reference to lhe solicitation and this amendment. and is received nnor to the onen,nn
hour and date snecafied.
I 12. ACCOUNTING AND APPROPRIATION DATA (If required)
Mod1fication Amount: $6,250.000.00
; See Schedule Modification Obligated Amount. $6,250,000 00
; 13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
I Check One A. THIS ORDER 10 ISSUED PURSUANT TO· (Specify au1honty) THE CHANGES SET FORTH IN ITEM 14 ARE MADE
IN THE CONTRACT I
ORDER NO. IN ITEM 10A
I i
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE AOMINISTRA TIVE CHANGES
I
I
office, appropnallon date. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
(such as changes In paying
' C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF.

'
I X Mutual agreement between both par1ies.
0 OTHER (Specify type of modificalion and authority)
i
IE IMPORTANT· Contractor r
,snot. r5<
Is required to sign this document and return copies to the IssuIng office. '
;~ESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, includrng solic~alion/con\ract subJect
matter where feasible)
[,o,p1 as f"O'"ded her~1n, all :eons and cond",ons ofll>e document r~ferericed ;n •!em OAor 10A. as heretofore dlanged, rema,ns
uncl1&"9e<land jn r<JII
force and ell'eCI
15A NAME AND TITLE OF SIGNER (Type orpnnt) : 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
l~•cholas Chung
r02•377•3635 rncholas chung@ed.gov
'58 co,,,RACTQR,offEROR ~ j
i
>SC DATE SIGNED , 168. UNITED STATES OF AMERI 16C. DATE SIGNED
b)(6)
! JLb-)(6-)-------~----rJ-- ( APR,,('2011
I (Signa1ure of person au\honzed to sign)

?-it
\Signature of Contracting Officer) I
'lSN 7540-IJl-l."i~-80~0 SI A'.\DARD ~OR.\! JO. (Rt1. I0-83)
Prcv1ou,; hJ,uon unmmt>k
Pn::scrihc<l by GSA FAR /4R CFR) 53.143
Supplementary Page
The purpose of this modification is to add funding for operations and system enhancements.
The current not-to-exceed limit is increased by $6,250,000 from $58,969,578.10 to $65,219,5

78.1 0.
All other terms and conditions remain unchanged and in full effect.
PAGE 2 OF 3 ED-FSA-09-0-0014/014
- - ,----
ITEM NO. '
Acqu1s1t1onPlan Request Number FSA000060. Title IV

Addrtronal Serv1cers (TIVAS)
SeMcing Operations
0008 • Pennsylvania Higher Education Assistance Agency to 1 00 I SE 6,000,000 00 1 6,000.000.00
I provide servicing operations.
!
IAccoun!1ng and Appropriation Data:
I0202A2011.B.2011 ENB00000.6CA
i $6,000.000 00
2521A.AB5.000.0000 000000 I
iOELIVERY DATE: 09/30/2011 I
'SHIP TO·
Contracts & Acqu1s1tionsMgt.. Group C
US Dept of Education. 550 12th Street SW, 7th Floor
1FOB Destination
j Enhancements
0009 IPennsylvania Higher Education Assistance Agency to 1.00 SE 250,000 00 250.000 00
provide enhancements to current servicing system
I Accounting and Appropriation Data:

!0202A2011.8.2011.ENB00000.6CA.2521A.AAJ.OOO 0000 000000
$250,000 00
1DELIVERY DATE: 0913012011
1
SHIP TO:
Contracts & Acquisitions Mgt . Group C
US Dept of Education. 550 12th Street SW, 7th Floor
FOB Oestina!ion
PAGE 3 OF 3 ED-FSA-09-0-0014/014
1 Con\'act :D Code Pa_ge_

of_Pageo
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT
- - ___ 1 '
l_ __ 3
·-? /\MEr-Df!c:Nf MOD FIC/\TION r-O. 3 FFFECTiVE: DATE 4 REQUISlilONIP\.JRCHASE-Rf'Q- NO - ·;·r:, PROJl::CT NO (ii dµ~i:cab·c)
!
015 MAY20, 2011 EDOPSA-11-0C0460 I
----~-------0 ------------~----- ------ ----
G ISSUl-'J :JY CODE FSA-FS2 7. ADMINISTERE:D BY (If other er.anI'.e'll 6) COUE:
•Jn,tcd S:a:ca lJccartrt·en• ::' F.dccat,an
FeJ~r": s:.r,en: f-. d:V:,ss,cn Suppur, Gro"u See Block 6
ilJ8 I.rs'. S'. ~E Sa.te 91D
fl Ni\\~-= /\'.JI) A"JrJRLSS Or' CONTR/\C-OR (NO, Street, Country, State and ZIP Code)
l'l"N"'SY _\1/\NI/\ H'GHHS l:DUCAT CN ASSISTANCC: AGENCY DUNS. 007368103 VI
1200r-7rHST CageCocto:41UK7
f-'.Nl:'i.lSBURG l'A 171021419
9B D/\lED (SE::l 1·1E:M 11)
10A fiOCIF,CATiON OF CONTRf1C:-/ORD':R NO
X
10B DAllD(SITIH"M1J)
i-----------··---------------------------'
C0 1)F :-i0:)30774 FACILITY CODE JUN 17_2009
--------·--·---·1_1. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
D 'ne abeve numbcrod sol·c1tat1cr IS amended as set fo:th in item 14 The ho~r and date specified for rece,pl of offers D
i;; t:xtenuod O
lb r,ot exte<id~d
O'.!r1rsrnuo'.ac~nowledge rccci:1t of tris amendment prior to the hour and dale specified 111 or as amended. by or.e ot the following mc~hoos:
the sol1c1tat1on
IJ) f3y comp,ct1n~ ,terns 8 ar.d 15, a~d returning ___ copies oi amendment: (b) By acknowledgmg receipt of this ame11drr,entor oaci", cooy of t11eoffer ~,,tm:r·ter:t·
01 (c; l::iy scpar Jt~ letter or teleg,am which 111c;udesa reference to the solic1ta1LOn
a:id amend,nent numbers FAl~URE 01 YOUR ACKNO'Ni.F.DGM::r;T TO RI
ISECf::IV:n /,T Tl-iF Pl.ACE: Dt:SIG~;A~ED f'OR ThE RECEIPT OR OF;cERS PRIOR TO THE HOUR AND DAT[ SP<'.CIFIE.'.D MAY RESUL.~- 1N Rl::_·f::CI ION Of-
YOlJ'S Clll'R If by wtue of ti% an'endment your dcsr,e to change an offer already subm.tted, such c~ange may be r,-,ade by telegram or let:er prov,llcc e:icl1
lc!PgHrn or ,-.1:P1 makes referericu to the so·,c,:atcon and this amendment, and 1sreceived prior to the opening hour and date spec1f1ed
~ 12 ACCO_;N'I \'Gi'iNoAi"'1;1~0l'RIA'I ION c:JATA(If requ,re3) Moa.11::a!IOr: A1'10Jfi·sh.C'i.io:Cccf us
Sec Schedule :vlodi'1cat1on Obligated A'11our'. SG COGOOCCO
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO, AS DESCRIBED IN ITEM 14,
Tc:IS Oll.Dl::I< ID ISSUE-_[)PURSUAN - · 0. (Specify aLlthor1ty)THE CHANGES SET FORTH IN ITEM 14 ARE ~'AUE:.IN T:-i::' C!)N I ciAcT
ORDER NO !N'li::M10A.
e ~Hr. AllOV[ '-JU//BERrn CONTRACT/ORDER IS MODIFIED TO RFFU:'CT THE ADM:NISTRATIVf- CHMJ6f'.'i f5i,C'~
do chn•.,;e~ 1npa)'-,lJ
of'ocu, ap~1opr:at1ondate, e:c\ Sf"T i=ORTII :N ITEM 14, PURSUA~T TO THE AUTHORITY Of FAI~ 43 103(b)
-·c--TI-IIS SUPPUC.Mf:NTAL AGREEMENT IS ENTER!::D INTO f>L;R$LJANTTO AU-f;ORl7Y OF·

X rJIJ'.uai<Jgreerner: betwee1 both parties
;
E IMPORTANT Contrac10" I i~--~~.!_-~ l:'__r:::g_uir:::!._~o-~~
:his -~9~u77e'ltand r_e)~-~~-"~ coo1~~t~ )he issuing offce _________ _
14 D'::SC~!I" 1 ON OI· 1',ME"DMl'l';7/MOD!FICATON (Organized by UCF section headings, includ,ng solic1tatio1,lc~ntr;ict subject mattr., wt1s-rereas,~le)
MAY23 7:J11
(S,9r.at.ire of rerson authoriLed to s,gn)
",:,'-, 75-lll-Ol·l5:?.-~IJ71J SJ'.\'.\DAR!l FOH\1 JO. (Rn. I0-83)

l'i,:, H1'h I ·,ht1n,i 111111,ab:,, l'r~,lnhd h)· (i'~,\ ',\I< 1-1~(TR) 53 ! l.l
Supplementary Page
The purpose of this modification is to add funding for operations and system enhancements.
The current not-to-exceed limit is increased by $6,000,000.00 from $65,219,578.10 to $71,219,578 10
All other terms and conditions remain unchanged and in full effect.
PAGE 2 OF 3 ED-FSA-09-D-00141015
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY i UNIT UNIT PRICE $ AMOUNT$
Acquisition Plan Request Number FSA000060 - Title IV

Additional Servicers (TIVAS)
0010 '1Funding for Title IV Servicing 1.00 SE 6,000,000.00 6,000,000.00
'Accounting and Appropriation Data.

0202A2011 B.2011.ENB00000 6CA 2521A AB5 000 0000 000000
$6,000,000.00
DELIVERY DATE: 09/30/2011
: FOB Destination
PAGE 3 OF 3 ED-FSA-09-D-00141015
0 00 01
AMENDMEN,cT~O_F_s_o~L-IC_1_T_A_T10_TN,/MCO=D-IF~1-c_Ac~T
..1_o_N'O~F~C-O=N
..T-R~A~C-T='°'C·CCo~c-lrn~"-'
_ , _de~===-·-p'-'llt --fag_~s,
----<
2. AMENDMENT "10DlflCATION NO- I 3. EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO. , 5. PROJECT NO 1if apphcable)
017 JUN 30, 2011 i
6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY ,:If o1her than ,tern 6) CODE
Urnted Stales Department of !::<lucat,on
! Feoeral Stude~( A1<l'M,ss-on Support ,:;,oup See Block 6
830 Fors! SI ,\JE - Su1le 9 IF3
Wastung1on ;JC 20202
Juha Jones
C-(1_NAME AND ADDRESS OF CONTRACTOR (NO, S1reet. Coun1ry, Stale and ZIP Code} I (x) 9A AMENDMENT OF SOLICITATION NO !
' PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY DUNS· 007368103 ,--'--'---
1200N7THST Cage Code· 41UK7
HARRISBURG PA 171021419 I
9B. DATED 1SEE ITEM 11)
c---h==============~'
10A MODIFICATION OF CONTRACT/ORDER NO.
CD-~3M~-G-0!4
X
10B DATED (SEE ITEM 13)
i CODE 0003077 4 i FACILITY CODE JUN 17, 2009

D The above numbered solicitation 1s amended as se! forth in item 14. The hour and date spec,fied for receipt of offers D ,s extended. Dis not extended.
, Offers must acknowledge receip1 of th,s amendment prior to the hour and date specified in ltle solic11ationor as amended, by one of the following methods:
I (a) By comp lehog ,terns 8 and 15, and retummg __ cop,es of amendment; (b) By acknowledging receipt of th,s amendment on each copy of the offer submitted;
or (c) By separate letter or 1elegram which includes a reference to \he solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
1 RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER. If by virtue of th,s amendmen1 your desire to change an offer already submitted. such change may be made by telegram or letter. provided each
, teleQram or letter makes reference to the sot.c,ta!ion and 1his amendment, and is received nrior to 1he oneninn hour and dale snecdied.
n2 ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount. li0.00
, See Schedule Modification Obligated Amount $0 00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER ID ISSUED PURSUANT TO· {Specify authority) THE CHANGES SET FORTH IN ITEM 1-4ARE MAOE IN THE CONTRACT
r-----~ ORDER NO IN ITEM 10A
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes 1npaying
off1ce. appropriation dale, elc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103{b)
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY Of:
X ; Mutual agreement between both parties.

'' D. OTHER (Specify type of modifica1ion and authonty}
E IMPORTANT Contractor r 1s not. Ix 1s reqwred "'"''"-"""'"""m"c~"s~>'°""''"c'c'>'c'Chce."''''"""'°"''-"'"ffi

to sign 1h,s d_o~_m'!"'"'''
14. DESCRIPTION OF AMENOMENTIMODIFICATION (Organized by UCF section headings. onclud1ngsoliatationlcontract subject matter where feasible)
I L•~I 3s ovrded ~ere,n, all terms aml cono,~onsnt om,doc)Jmenl relere~c,,,J •n ,\em 9A o, 10A. as herelo!ore cl>an ed. remain• ,onctian ed and in full force and etfed
, \To5 NAIDAND TITLE OF SI NER (Type or pri'11) 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or pnnt)
i ' ' . ·-;-----,.
C:::.,1,-•-:-: /1 Nicholas Chung
i \ ·- 1..,0 ~-__.) ,~·-"_).:-::t../~ foz-377-3635 nicholas chung@ed gov
:\J0.,.V-o" 'fYl U'~fltl l.c.or1Si;(lLU

/Y: I
168 UNITEO__
§T@_ES_OF AMERICA 16C DA TE SIGNED
Q.f££f_WR 15C DATE SIGN
'
:tLb=)(=B=)~~~-~~~-----,--'-1;3□[ 06. 20 I.,__

tS1gnatc1reof person authorized to sign) 1s1gnature of Contracting Officer} 1
\iS'- ~~•ll)-(I I- I 5~-H070 ST,\'iDARD FOR\I 30. (Rev. 10-83)

!'rc,ious [d11,0n tn111,abk ?n:scrib◄:J l>) OS!\ L\R (-18 Cl'R) 5.1 ~--1.,
Supplementary Page
The purposes of this modification are as follows:
1. Replace the Allocation Metric #1 incorporated in Attachment A-4 Ongoing Allocation Methodology of the
base IDIQ contract with the following language:
"Allocation Metric# 1 - to be measured Quarterly (calendar quarters beginning with October 1, 2009).
Calculation= (Total Dollar Amount that are 361 + days delinquent within the current quarter) DIVIDED BY
(Total Dollar Amount that are in Repayment and Oto 360 days delinquent plus the Total Dollar Amount that
are 361 + days only within the current quarter). All available quarterly scores in each category (1a, 1b, 1c)
will be averaged together on July 1 of each year to calculate the Final Score for this allocation metric."
2. Replace the Allocation Metric #2 incorporated in Attachment A-4 Ongoing Allocation Methodology of the
base 1010 contract with the following language:
"Allocation Metric# 2 - to be measured Quarterly (calendar quarters beginning with October 1, 2009).
Calculation= (Total Count of Borrowers that are 361+ days delinquent within the current quarter) DIVIDED
BY (Total Count of Borrowers that are in Repayment and Oto 360 days delinquent plus the Total Count
of Borrowers that are 361+ days only within the current quarter). All available quarterly scores in each
category (2a,2b, 2c) will be averaged together on July 1 of each year to calculate the Final Score for this
allocation metric."
Alt other terms and conditions remain unchanged and in full effect.
PAGE 2 OF 2 ED-FSA-09·0-0014.'017
1 Contract ID Code Pag_eo_f~g~s __

7 AMf'NDMENT MODIFlc/\TloN·==---~====~~~=====±c===~~===+~-c'~g
NO 3 F.FFECTIVE DA.TE 4, REOUIS!TION/PURCHASE REQ. NO. 5. PROJECT NO (if applicahlr)
018 AUG01,2011
~ ISSUED BY--~~------C-O-DEL"F"S~A~.,;s~,~=cc--+ l"'h-ac-,",e_m_6"}L.~c"o0□"E______
0,-. A"'D"'M"l"N"'IS"T"E"R"E"D"'B"Y"l"'ll-,"11,-,", _
Un,tec S'ates Depart,ner,t of EduCs>t1on
Fede,~I Student /\1dlM.ss1onSuppcrt Group See Block 6
830 Ftrs'.SI ~E - Suite 91"3
'N~sh;ngrn11 DC 20202
Jul,a Jones
---··
8. NAME ANO ADDRESS OF CONTRACTOR (NO .. Street. Country, State and ZIP Code} 9A AMENDMENT OF SOLICITATION NO
PENNSYLVANIA HIGHER >.:DUCATION ASSISTANCE AGENCY DUNS: 007368103 (x)
~
120() N 7TH ST
Cage Code. 41UK7
'
9B. DATED (SEE ITE'v\ 11)
I
!
10A MODIFICATION OF CONTR,\CTIORDER NO.
"cl! •SA-l!SJ OJM
''I
__ X ------ ' -
'
10B. =iAT[D (SC[ ITEM 1JJ
.,_,
--·--
l
'
COUF 0003077 4 f'ACILITY CODE JUN 17, 2009

' ·- ····---·- ------- ·-------<
D The above ;;umbered so11citationIs amended as set iorth in item 14. The hour and date specified for receipt of otfer5 D is extended, Disnot exlendell.
orrers nIust a6mowledge mcoipt oi lh1s amendment prior to the hour and date specified in the solicitation or as amended, by one ol the following methods:
(a) By completing i1ems 8 and 15, and returning ___ copies of amendment: (b) By acknowledging rece,pt of this amendment on each copy of the offer submitted;
1
or (c) By separate letter or telegram which includes a reference to the solicitation and amendrnent numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT lHE PLACC: DESIGNATED FOR THE REGEi Pl OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN Rl':Jf:CTION OF
YOUI~ OFFER. If by virtue of this amendment your desire to change an offer already ~ubm1\ted. such ct,ange may be made by telegra'Tl or letter, provided each
, telegram or lcl!er makes reference to the sol·citation and th:s amendment, and Is received prior to the opening hour and dale specified ____·-···---·
r,2. ACCOUNTING AND AP.~ROPRIAl'ION DATA (If required) Mod1f1ca\1on Amour\ so 00
See Schedule Modification Obligated Amount SOOD
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14.
C!1eck One A. THIS ORDJ:'R lr1-ISSUED PURSUANT TO (Specify authority) fHE CHANGFS SET°FOR'fH]f,Tl'fI~)'.fT4 ARE MADE IN (Hi: CONTRACT
'-C'.'.'.:=.c'.'.'_J ORDER NO IN ITEM 10A
8. THF. AROVE NUMBERCD CONTRACT/ORDER IS MODlf-lt::D TO RE:f-LE:-CffHE /40MINIS'lf~ATI\/1tCHANGES (SlXh as cr,anges in paying
X office. appropnatIon date, e1c} St:T FOrnH IN ITEM 14, PURSUANT TO -,-HEAUTHOR!TY OF FAR 43.103:b).
C. THIS SUPf-'Lt:MENTALAGR[CME:NT IS F.NTERED INTO PURSUANT TO AUTHORITY OF
D. OTHER (Specify '.ype of modific;it,on ;ind authority)
~---·-'----------------------------------------------,
E IMPORTANT: Contractor I is not, r5<Is required to sign this document and return copies to !lie issuing office.
14. DESCRIPTION OF AMENDMENTIMODIFICA TION (Organized by UCF section Madings. inciud,ng sol,c1tatIonlcontrncl subJCCImmter where leas1ole)
fc,ce~t a, pra•✓ 1de:J herein. nil termsand ccl1d,1,oc>suf thnaocwnent·e•erenced ,n ,tern9A or \QA, a.slior~toforecl1a~ge:J,
rema11.s uach~nged and111
full !o'ce and eHcct
J5".' NAME.AND TllLE 0~ Slf!'JER ( fype or print) 16A NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
·\\ "\.--\ 1170,, -1 ~\ -.{)_,:._r:r, ,Nicholas Chung
I tA"Tll (,1-A---'" I.~J "-.Jl..>J0.''- 12()2-377,3635 n1cholas.chung@e<l.gov
~.v~
¥s¥~ll'££~~~:P,ru;c-k~ CY,~~,N:£~a'~s:uNITEDSTATESOrAMffiTtA:- -- ,Be DATe SIGNED
____ .
rb}(B}
(Signature of person aull1onzcd lo sign)

L <61
1 111 ====~
~Lal(b}~(B}
rSirmature of Contr'iic11nn-otttcen· ----

AUG 02 2011
l\J'.-il\ 7.'i,1/HI1-1,l-8(J70 SI..\:\ D.\RJ) l· OR\! 30. (Re,. 10-83)

1'r..:,·io11s
1·ct11inn
um1~,ohk Pr-·,cribed 1,y G'.'..A ! ,\H (48 Cl·R) 53.243
Supplementary Page
The purpose of this modification is to add to Patrice Washington as an Alternate Contracting Officer's
Representative under this contract #ED-FSA-09-D-0014 with Pennsylvania Higher Education Assistance
Agency (PHEAA). A copy of Patrice Washington designation letter and COTR certification letter are
attached herein.
All other terms and conditions of this contract remain unchanged and in full force and effect.
PAGE 2 OF ED-FSA-09-D-0014/018
Supplementary Page
PAGE 3 OF EO-FSA-09-D-00141018
MEMORANDUM
C S. DEPARTMENT OF LDLCA TIO:\'
TO: Patrice \Vashington

FROM: I\'icholas Chung, Contracting Officer
DATE: July 29, 2011
SLBJECT: Delegation and Appointment of Alternate Contracting Officer's Representative (CORJ
for the procurement of J'itlc IV Additional Servicers Program (TIVAS) under the
provision of Contract l'\o. FD-fSA-09-d-0014 dated: June 17, 2009 with Pennsylvania
Higher Educc1tionAssistance Agency (PHEAA).
1. This is tu certify that Patrice Washington is hereby appointed as the Alternate Contracting
Officer's Representative (ACOR) for the ahovc referenced contract. You will be the activated as
the COR, \Vhcn COR, Tammy Connelly, is not available to conduct the COR duties.
2. This appointment does not replace your current appointment as primary COR on your respective
agreements nor dues it replace/remove Veer Sain as an ACOR.
3. This designation will remain in effect from contract award through contract termination unless
sooner terminated in writing by the Contracting Otlicer (CO) or successor. or by reason of your
reassignment, resignation. termination or noncompliance with FAC-COTR Certification
maintenance requirements.
4. The CO is to be notified immediatt:ly if you m.:civc notice of reassignment, or when you will be
absent for an extended period of lime or othcrv.-ise be unable to fulfill the responsibilities of this
position. In your ah~ence, notificution is to be given by your immediate superior. You are required to
maintain current FAC-COTR certification in accordance with program rcqmrcrnents.
5. The CO is the exclusive agent of the Government with authority to cnlL'r into and administer
contracts. Thus, the CO has the responsibility to sec that al! requirements of law and regulation are
followed. However, as the CO's representative you are delegated the authority to monitor the
technical effort being performed under the contract. You should familiariJ:e yourself with the
requirements of the contract, and communicate with the Contractor as necessary to ensure the
contractor is making satisfactory progress in performance ofthe contract. Other than the CO, you are
the only Government employee who may direct the flow of technical matters between the
Government and the Contractor.
6. A contract is a legally enforceable agreement that contains the rights and remedies of the parties. If
the Contractor deviates from the terms of the contract, it is a matter between the Govemmi;:nt
(represented hy the CO) and the Contractor. You must keep the CO folly infom1cd so that legally
effective solutions can be applied to problems as they develop. Your suggestions to the Contractor
may be construed as instructions and lead to claims for additional compensation or to a release oflhc
Contractor from it~ obligations under the contract. Suggestions sometimes work out, but often lead
to misunderstandings. Therefore, while you can and must make technical decisions, do not take any
contract administration actions unkss tlwy arc clearly authorized hy this appoh1tment.
7. (I.LTflORITY AND DUTJES: You are hereby authori1;ed by this designation to take any and all
action with respect to the following which could lawfully be taken by the Contracting Officer, except
any action specifically prohibited by the terms of the subject contract and paragraph 7.
"LIMITATIONS'', of this designation.
a. To monitor and to assure that the Contractor perfonm the technical requirement of the contract,
to include inspection and testing of delivcn1blcs and evaluation of reports in accordance with lhc
contract terms_ conditions, specification and drawings. Ensure any inspections performed are
PAGE 2 OF ED"FSA-09-D-00141018
t1ccess<1ryto assure compliance with all contract technical requirements and require the
Contractor to correct any deficiencies. t;pon technical acceptance of completed work for the
government complete a record of inspection and acceptance on the ·'Material Inspection and
Receiving Report", or other applicable form. When reports /forms are prepared ensure they arc
forwarded to the CO.
b. As the individual named in lhtc contract as the COR, you are the sole person (other than the CO),
afler appropriate coordination with the PM. with the authority to communicate technical
din;ction or to recommend final acceptance or rejection to the CO.
c. To prcpm-c a COR Work plan and establish and maintain appropriate reu1rd-keeping files.
d. To rcviev.., evaluate and comment on any aspects of the contract and its performance to include
problem areas, proposals, and technical issues, and to make written recommendations to the
e. To communicate and coordinate directly with the Contractor to the extent necessary to carry out
your duties as COR except as prohibited in paragraph 7, "LJMIT ATIONS" of this designation.
f. To attend post-award, negotiation, and other conferences. Assist and participate in the post award
orientation.
g. To coordinate site entry for Contractor/Government personnel as appropriate,
h. When site visits arc conducted, compare actual accomplishments v...ith scheduled and report
perlonnancc. Be alert to changes in technical performance that may affect the financial status,
personnel, or other elements ofperfomrnnce.
1, To ensure that Government Furnished Property (GFP), if provided in the contract (including
software), is available when required and proper documentation is obtained when such property
is transferred. Review the contractor's property control system and software rnnfiguration
management to ensure compliance with Government property clauses and re<.:ommend to the CO
either approval or disapproval of the system.
J. To ensure accountability of GFP and Contractor Acquired Property (CAP) is established upon
receipt of the property and an auditable record of ownership is maintained (Leased Property must
be included), Ensure that al! Government property, \~hether government furnished, nintractor
acquired. leased or contractor fabricated is properly labeled and identified and that the property
records are created and maintained.
k. To monitor the acquisition, control, and disposition of Government Property by the contractor.
Require reports by the contractor for any loss, damage, or destruction of property. To verify
maintenance activities arc performed.
L To ensure the contractor, in accordance with L\R 45.508, conducts accurate and timely periodic
inventories a<.:cording to an established schedule approved by the Property Administrator. Have
tbc contractor submit electronic reports indicating the results of the inventories performed.
Document upon discovery any discrepancies, or upon identification of misuse or loss. and
resolve all discrepancies.
m. To provide appropriate notification to the CO in any instance when his/her immediate or
expeditious decision is required. lmmcdiatc!y report contractor performance problems to the
C0.1CS.
n. To prepare a written evaluation of the contractor's performance within 45 days aflcr completion
of any contract.
o. To provide to the CO sufficient evidence of a breach, and sugge.<,tionfor an appropriate contract
remedy, if a breach of contract is identified and assist in evalwting contractor response.
p. To assist the CO in determining whether to terminate a contract.
q. To review progress and financial reports. invoices, vouchers, and recommend approval or
disapproval hy the CO. To enter receipts into the Contract and Pur<.:hasing Support System
(CPSS) after review of invoices/vouchers. In cost-reimbursement contracts exceeding $100.000
estimated value, verify confonnance with the clause "Payment for Overtime Premiums" Also
recommend approval and disapproval of overtime in Labor-Hour or Time-and-Material

contracts. Review and make timely rernmmendations to the CO as to the approval. disapproval,
or other action to take concerning a contractor's submission of (or failure to submit) payment
requests. deliverables. interim or final progrcs5 and financial reports, or any other requirements
of the con1ract. Maintain a record/summary of payments to date to ensure that short-term
progress is viewed as part of the whole to help monitor payment expenditures against total
obligations.
r. To maintain c:illnecessary records to document and describe thi: performance of your duties as
COR, and to distribute such records as applicable. You arc required to submit annual ,.,,Titten
performance evaluation.5 to the CO concerning the Contractor's progress and perfonnancc of the
work or ikms delivered. You arc also required to submit any other reports as indicated in the
Contract :\1onitoring Plan. !f your designation is terminated for any reason before completion of
the contract, you will tum over your records to the successor COR or obtain disposition
instructions from the CO.
s. To provide advice and assistance to the CO in other areas of contract administration which arc
not specifically covered in this designation. Keep the CO informed of all communications with
the contractor in order to prevent possible misunderstandings or situations that could become the
basis for future daims against the Government. Only the requirements written in the contract can
be asked of the contractor. If additional requirements seem necessary, discuss them with the CO
and PM, but do not try to enforce them unless the CO modifies the contract in writing.
t. lo review and recommend in writing contract modification requests or changes to the SOW and
period of performance necessary to ac(;umplish the objective of the contract. Prepare a technical
evaluation to support a determination that the change is not outside the scope ufthc contract. For
contrackir initiated changes, direct the contractor to submit a written description that includes the
effect of the changes on the contract terms and conditions. RcYicw the submission and send it to
the CO with your recommendation.
u. To recommend, in writing, to the CO whether an option should be exercised under the contract
(given a contract awarded with options and an option clause). Submit market research data to the
CO to support the recommendation to exercise the option.
v. To submit prncuremcnt request(s) for additional services/tasks.
w. lo assist the CO, if asked, in administering Stop Work Orders.
x. To notify the CO about a delay in the delivery or performance schedule under the contract.
y. To assist the CO in analyring a claim, recommend a settlement position, and par\i(;ipatc in thi:
resolution process.
;:., 'Io advise the CO, at the completion of the contract, as to the receipt of al! items, services and
reports required under the contract, and the compliance with all contract provisions. Also,
rernmmcnd a disposition of any Government Furnished/Contractor Acquired Property in the
possession of the contractor, and verify the usage of any Government-owned consumable
furnished under the contract.
aa. To ensure that security requirements for contractors are adhered to in accordance with ACS
D1rc(;tive OM: 5-101. Contractor Employcc Personnel Security Screenings.
hh. To inform the CO in \Hiting of any work being performed by the contractor thm is not
authorized in the scope of the contract.
8. LIMITATIO\/S: You are prohibited from taking any action with respect to the following:
a. To authorize commencement of work at the beginning of a contract, or m circumstances
involving an increase of work. unless and until the Contracting Officer ha~ authori,-ed the
Contractor to proceed lo work.
b. To encourage or approve, by word, actions, or omissiom, any action by a contractor which

would require the Contracting Officer\ approvaL bu! has not received approval from the
c. To award, agree to, or sign any contract (including delivery and purchase orders) or modification
thereto, or in any direct or indirect 'Nay to obligate the payment of money by the Government.
J. 1 ogive mstructions or to make ru1yfom1 of agreement whi.:h alkcts the unit price, total contract
price, quantity, yuality, dcliYcry schedule, or scope of work. Only the Contracting Officer can
provide instructions and agreement~ of this type,
9. Unauthori1.cd obligations made in relation to this contract must follow ratification procedures. Any
unauthori,:cd obligation may be dcnicd by the ratifying official, leaving the individual who made the
obligation pcrsonaHy liable. You must immediately report to the CO any unauthori1:ed obligations
that come to your attention.
10. The COR may nominate an assistant to act as his/her representative as a result of his/her absence;
however, the nominee mu~t be ofiicially delegated the appropriate duties, in v.Titing, by the
11. \Vritten communkalions with the Contractor and any other contract related documcms shall be
signed as "Contracting Officer's Representative" (COR), with a copy furnished to the Contr.icting
Officer.
12. By signing below you certify (hat yot1 have read. understand and agree to these instructions. You are
also required to .idnowledge receipt of this designation (or tem1ination) in the space provided
belov.. Return the original acknowledgement within ten (JO) days to the Contracting Otfo:er for
retention in the contract tile. A duplicate copy is pro\-ided for your records to be maintained in your
COR files.
rb)(6)
--(--
Contra~e~- Date
RECUPT OF THIS DELEGAT[O:,.: AND APPOINTMENT IS HEREBY ACKNOWLEDGED.
zr:llf:A
HAVE READ A\/D FlJI.I_Y LINDERST AND THE AL;TI!ORITY AND Ll\.11TArIONS
'\J ;_
COR ~~ Date
2-D2- 3-,7, 3%5 °]

Telephone Number
FOR CONTRACTOR USE: Receipt of the contractor's copy of this delegation and appointment is
hereby acknowledged. I have read and fully understand the authority and limitations of the COR.
Contractor Signature Date
\f\>....
tt0~1LXini1u;re.tlr-
litlc (:::)
s;pntoc,.n;:;xr\;,~-,
Company
· ?
..
This Dt:lcgation and Appointment is hereby Termim1tcd effective---· without

prejudice to any actions taken pursuant thert:lo by the appointed COR.
~-~-~------- ---
Contracting Officer Signature
Receipt of Termination as COR is hereby acknowledged:
COR Signature Date
cc
Contractor
Conrrac/ Fifr
Program },tanager
PAGE 6 OF ED-FSA-09-D-00141018
FederalAcquisitionCertific
ation
for
Contracting Officer Techn
ical Representative
Patrice D. Washington
~m Has met the required 40 ho
urs of initial training
'0
' Date of Issuance: . No_v
em.ber_2fl,
2008
m
0
' ,,· '.''•\ FE

DERAL
"'
~
9
0
,: \f
\;·,"
il d
AC,\
QUISITIOfl
0
~
INSTITUTE
'ii
~1
m
j
Karcr, Pica
D.rector. Fece,al Acqu1soi, Hugh J. Hllrv,ltt
onlnst,iu!e
Sen,o, Procur€men: E~ecu1iv
e
Depar.ment of Education
FSA090014-0l9
Contract m Code
04
0,~P"R"O","E"C"T"N"0~(",1-,"e",,-,~---
J crrrcw,E DArE 1lSE-P.E:"o~N"0~~
,( Ri::"_Q"U"IS"l"Tl"O"N"if-;LIRCf c'b"le")'--j
0 19 SEP D7, 2011 EDOFSA-11-001002
6. ISSU(O"H"Y~--" .CC ---- C(f[)f F-SA-FS2 -- 1 ··7 ADMINIS fERE6·3y (ttoltie°rcf"ha"a~ire"1"""6")-~C"O"D"E------------i
JMed Slates Department ol Edu<;<1tio1
'""~"' St~tJenl Aid/Mi,sion Support Group Seo Block 6
830 F:rst St NE - Su~e ~1F3
'.lvash.~gton DC 20202
Jul,~ Jopes
~'l:'\!1.f /1NJ:;A"66~E:ss I
I OF CONTRACTOR (NO., Street. Country, S!a!e and /IP Cu,1ej"
PENNSYLVANIA HIGHER EclUCA1fON ASSISTANC[ AGl::NCY DUNS 007368103
i 1,1 9A N,lf'NOMENT OF SOL/C:TATION NO
!
: 121JON7JHSr CageCode:41UK7 I
II 98 DATED (SEE /TEM 11)
ii
I
I - --
10A MUDIFICATION oF c6NTRACT10RoER-NO--:I
~0-i'SA-,'.;9-D-001, '
X
108. DAffD (S[E ITEM 13)
i CODE 00030774 I fACILITYCODE JUN 17, 2009
, 11. THIS ITEM ONLY ~PPLIES TO AMENDMENTS OF SOLICITATIONS
I
r ·o -~he above numbered sohcllabon is amended as sel forth in item 14. The hour and dale specilic:d fur r~elpt of offers □ ~-
Offers must ack.nowtedgc receipt of this amendment prior tu the hour and date specified m :he S•Jtici!ation or as amendod, by one o( tf'e followmg methoi;Js·
exleoded, DIS not extended.
(a) By completing items a and 15, and returning,---~ copies of amendment. (b} By ackoowledging receipt"' lhls amendment on each copy of the offer subrn11ted:
or (c) By separate let:er or telegram whicl1 includes a reference 10 tne solic1ta1ioo and amendmen1 numbers FAILURE OF YOUR ACKNOVI/LEDGMENT fO fl[
RECEIVED Ar lHE PU\CE DESIGNATED FOR THE RECEIPT Of{ OFFERS PRIOR TO THE HOUR ANO DAT[ SPrClflED MAY RESULT IN REJECflON OF
YOUR OFFER If b1•111rtueof !his amendmerit _yourdesire 1? change on offe, already submil'.ed. such change may tx, made by telegram or !etter, pro video each
. l~arn or letter 1n11kesreference to the sollcital1on and this amendment. and Is race111edprior to H>eopening hour and date specified
112. ACCOVNTING AND ,o,Pf'ROPRIAflON DATA (If requtred) ---- Mod1ficabo!1Affi0Urii:$16,000,000 001
! See Schedule Modifica1ion Obligated Amount· $16,000,000 00-
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES me CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check Or.e A. TH!S ORDER-ID ISSUED PURSUANT TO (Specify a~,lhorlty) TI IE CHA~GES SET FORTH IN ITEM 14 ARE MADfiN'fHE"coNi''¼CT-
ORDFR NO IN ITEM 10A.
U, TffE ABOVF NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISfRAnvE CfiANGEs(SI.Jellas d1,w,1es !n payiny
I C.
office, 11ppropna!1ondate. e\cJ SET FORTit IN ITFM 14, PURSUANT TO THE /,UTHORln'
THIS S'J?PLEMENTAL AGREEMENT IS FNTERFD IN'r6PURSUANT

OF Ft,.R 43.103(b)
TO AUTHORITY O'"F
_________ --------~
Mutual agrc-ement between both parties. j
D. OlHER(Specify type of f'lCldificaton and Authority) -----1

'
E. lMPORTANT· Contractor f' 1s not, Ix i~ required to sign this document and return copies to the issuing offi c e __
00
~DESCRIPTION OF AMENDMENTIMCiDlfiCM ION (Organized by UCF section heat1ings, inchAing sollci!at!on/contract subject matter wtiere leas1~!e)
, E.>tcep!a< p,.,"1®'1 he,etn, e~ IPrm• an~ cond;1;on, c1 the documffit referP.nced

'" ~6m 9Ao, 1CA.~• hereto!ore cl,ar>ij•<I. rorMln• unchan~ed and ,n twl tore& ai,1 ~lfoct.
:·1sA. NAME ANO l lll.E oi: SIGNCR (':'ypc-:,r pi-!n1)
; Matthew D. Scsqa
-- -- -- ·I,16A. NAW:CAND llTLE CF CONTRACTING OFF'Ct:R){ype
Bradley Bumgarner
or print)
I VP and, Program Director, FedLoan servicing ;202-Jn-3487 Brc1dley Bumgamer@ed qov
I
(_150 CONT_RA_CTGi<IOH-EROR - 0176°B".
15C D/11 I:: SIG~ED '..____ 7fA'T~ESOF AMFRl'"C7A---~1
"U"ff"ITE"o"D~$ 767C~0 7A"TE:SIGNED
! r)(6) b)(6)
SEP 87 201"
(Sign~lurc ol person .:iuU1orizod to sign) I (Sinnalure of Contra Officer)·

NS>. 7540-0\-152•~0'0 S IA."./DARD FOR\130. (Rev, 10-83)
Previm,s Edition lln~sable Prescr:be.l by GSA F.A,R (48 ('FR) 53.~43
Supplementary Page
See Attachment A for modification description.
PAGE 2 OF ED-FSA-09-D-0014!019
r----
OBTAINED BY STUDENT BORROWER PROTECTION CENTER
----------- AND AMERICAN
----------- -~-FEDERATION
--- OF TEACHERS
----------UNDER
SCHEDULE Continued
----- THE FREEDOM
-s•----- OF INFORMATION ACT -7
~----;;;-,-o--i--------.-UPP~IESISEltVICES
I
~- -"'-"-+--__"_"_'_"_"_'_'_
-- !~~o_, _"
---•i
--~
!(New Line Item)

Acquisition Plan Request Number FSA000060-
I I I
0013 I
, Funding for Title IV Servicing ,o) se 15_000.000 ool ,e.ooo.oooooj
IAccounting and Appropriation Data:
0202A2011.B.2011 ENB00000.6CA.2521A.AB5.000.0000 000000
$16,000,000.00
FOB : Destination
I
I
I
PAGE 3 OF EO-FSA-09-D-00141019
Attachment A
The purposes of this modification are as follows:
1. This mod1f1cat1onrevises the language identified m Attachm!.'nt A-1. Internal Controls No. 30 of
the Base Contract and replaces the Auditing Standards for Type II SAS70 r!.'ports with the
Auditing Standard for Type II SSAE16 The following is the revised requirement in response to
Change Request #1031:
Internal Control$
30. The servicer shall meet requirements for a Type II SSAE16 audit. It is anticipated that performance
of the Type I( SSAE16 audit with an unqualified opinion and submission of the resulting work papers will
eliminate or substantially reduce audit work performed by various auditors, internal and external to the
Department, as part of the Department-wide and Government-wide annual audits. As part of their
contracts with various lenders, servicers also norm.illy h.ive a SSAE 16 .iudit performed annu.ifly by a
qualified independent .iuditor.
a) For IT controls, the servicer sh.ill supplement the Type II SSAE16 with additional agreed-upon
procedures resulting in an audit consistent with GAO's Federal Information System Control Audit
Manual (F/SCAM). The results of these procedures should be conducted and reported at least
annually, with a ye.ir·end of 6/30. Further, the servicer shall provide FSA with .i "bridge letter"
covering !he period from 7/01 to 9/30 indicating no changes to the control environment.
b) For operation.ii controls, the servicer shall ensure that the Type fl SSAE 16 covers .ill GAO
Internal Control Slandards or COSO components (e g., control environment, risk assessment,
control activities, information and communication, and monitoring) for those transactions
processed by the servicer. The results of these procedures should be conducted and reported .it
least semi-annu.illy covering the periods 1/1 - 6/30 and 7/1 - 12/31.
2. Add funding in the amount of $16,000,000.00 for operations and system enhancements.
The current not-to-exceed limit is increased by $16,000,000.00 from 86,769,578.10 to $102. 769,578.10.
All other terms and conditions remain unchanged and m full effect.
PAGE 4 OF EO-FSA-09-D-OO14/019
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT ! ' cootrnct1Dcecte

Pag~9:f_P_a9es_
1 3
2 AMENDMENT MODIFICATION NO. 3 EFFECTIVE DA TE 4 REQUISITION/PURCHASE REQ NO. 5 PROJECT NO (if applicable)
020 SEP 23. 2011 EOOFSA-11-001074

6 ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other than item 6) CODE
Un,ted S1ales Department o( Educat,on
Federal S:udent A,dlM1ss1on Support Group See Block 6
830 F,n;t SI NE - Suite 91F3
W'asll,ngton DC 20202
Juha Jones
I '
8 NAME ANO ADDRESS OF CONTRACTOR (NO., Street, Country, State and ZIP Code) 9A AMENDMENT OF SOLICITATION NO
, PENNSYLVANIA HIGHER EDUCATION ASSIST ANGE AGENCY DUNS: 007368103 (x) !
~
I 1200 NORTH TTH STREET Cage Code: 41 UK7 !
1
HARRISBURG PA 171021444 9B DATED (SEE ITEM 11) I
i
I 10A. MODIFICATION OF CONTRACT/ORDER NO I
ED·FSA--C9·D•0014
i
X '
' 10B DATED (SEE ITEM 13)
'
I CODE 0003077 4 I FACILITY CODE JUN 17, 2009 I
I 11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
'
D The above numbered solicitation is amended as set forth In item 14 The hour and date specified for receipt of offers D Is extended, Dis not extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solic1tatmn or as amended. by one of the following methods
{a) By comple1ing items 8 and 15. and returning ___ copies of amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted:
or (c) By separate letter or telegram which includes a reference to the solic1talion and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR ANO DATE SPECIFIED MAY RESULT JN REJECTION OF
YOUR OFFER If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each
tel ram or letter makes reference to the sohcitat1on and this amendment, and is received rior to the o enin hour and date s ec1fied
12 ACCOUNTING ANO APPROPRIATION DATA \If required) Modification Amount: 100,000.001
See Schedule Modification Obligated Amount: $100,000.00j
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14. !
Check One A THIS ORDER ID ISSUED PURSUANT TO. (Specify aulhonty} THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
ORDER NO IN ITEM 10A
I
I X 52 212-4 '
;
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying
office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
I
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF·
!
D OTHER (Specify lype of modification and authority) !
'! i
E. IMPORTANT: Contractor Ix is not, I is required to sign this document and return copies to the issuing office.
'
14 DESCRIPTION OF AMENOMENTiMOOIFICATION (Organized by UCF section headings, including so(icitation/contrac! subjecl matter where feasible)
cond,I.,r,sol lha documenl mfe,...,,_,,d ,n 1lem 9A. or 10A.. as harn!ofora d1anged. rema,ns unchanged ~nd 10 h,11lon:e ~n<i effect
facap! as p,ov,da<l here,n, dll le<rns dnd
15A. NAME AND TITLE OF SIGNER (Type or print) : 16A NAME ANO TITLE OF CONTRACTING OFFICER (Type or print}
, Nicholas Chung
1202-377 ·3635 nicholas chung@ed gov
I
( _15B__
c:_o_~!_RAQ_()_f3.19£~_E]3,_Q_R
____. ____--- 15C. DATE SIGNED i 168 UNITED STATES OF AMERICA 16C. DATE SIGNED
!
SEP 23, 2011
I
(Signa1ure of person authorized to srgn)
(Signature of Contracting Officer)
NSN 7540•01 • I 52-X070 STANDARD HJR'\-1JO. (Re,·. 10-83)
Previous F.chliun llflll~ablc PrcsrnbcJ by (,SA FAR (--1-X
CFRl 5J.~--l-J
Supplementary Page
See Attachment A for Modification Description.
PAGE
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND2 AMERICAN
OF 3 ED-FSA-09-0-0014/020
SUPPLIES/SEl'IVICES
I(New Lme Item)

1
Acquisition Plan Request Number FSA000060 -
'
0014 Funding for Loan Consolidation Initiative. 1001 SE 100.000.ool 100.000.00
1
IAccounting and Appropriation Data: i i
1
: 0202A2011.B.2011.ENB00000.6CA.2521A.AAJ.000.0000 000000
$100.000.00
FOB . Destination
i
---- --------
PAGE
OF 3 ED-FSA-09-D
-0014/020
Attachment A: Modification Description
Modification 0020
ED-FSA-09-D-1Xll4 (PHEAA)
The purpose of this modification is to issue a Change Order pursuant to the Ch.:mges Clause
52.212--l. section B. l(C) of the base IDIQ contract for the follmving:
A. Dircl.'.tLoan Consolidation Initiative and Process Flow

I. The contractor is directed to begin work on this requirement as of September 23,
2011 in accordance with the attached requirements document (Ana,:hmentsBand CJ. as
applicable.
2. The definitive contract modification resulting from this change order will include a
negotiated firm fixed price in no event to exceed $100.()00.00.
The following tenns and conditions apply to both requirements above:

A. The Contractor shall begin promptly negotiating with the Contracting Officer the terms of
a definitive contract modification that will include all clauses required by law on the date
of issuance for the modification, and any other mutually agreeable clauses, te1ms. and
conditions.
B. Definitization Schedule:
I. Date for submission of the revised proposal with cost & pricing data and updated
subcontracting plan: October 6, 2011.
2. Planned Date of !he start of negotiations: October I 2, 20 I 1.
3. Planned Target date of dcfinitization: October 26, 2011.
4. Dale for submission of certificale for certified cost & pricing data: One business day
after final negotiation.
C. The Contractor shall provide cost and pricing <lata in accordance with FAR 15.408, Table
15-2 supporting its proposal for the following:
L. Actual incurred costs through <late of <lefinitization of this change order.
2. Work yet to he completed through completion of project.
D. If agreement on a definitive contract modification to supersede this change order is not

reached by the target date in paragraph (B) of this section. or within any extension of it
gramed by the Contracting Officer, the Contracting Officer may determine a reasonahlc
pnce or fee in accordance with Suhpart 15.4 and Part 31 of the FAR, subject to
Contractor appeal as provided in the Disputes clause. In any event. the Contractor shall
proceed \vith completion or the change order. subject only to the Limitation of
Government Liahility clause.
I. After the Contracting Officer''> determination of price or fee, the contract modification
shall be governed by:
a. All clauses required hy law as of the date of the Contracting Officer's
determination; and
b. Any other clauses, tem1s, and con<littons mutually agreed upon.
Page 1 of 3
Attachment;\; Modification Description
Modification 0020
EO-FSA-09-O-0014 (PHEAA)
2. To the extent consistent with paragraph (D)( I) of this section, all clauses, rcnns. and
conditions included in this change order shall continue in effect.
E. Payments of Allowable Co.sis Before Definitization

I. Reimbursement rate: Pending the dcfinitization of the change order referred lo herein,
the Government \Viiipromptly reimburse the Contractor for all allowable costs under
this contract modification at the following rates:
a. One hundred percent of approved costs representing financing payments to
subcontractors under fixed-price subcontracts. provided that the Government's
payments to the Contractor will not exceed 80 percent of the allowable costs of
those subcontractors.
b. One hundred percent of approved costs representing cost-reimbursement
subcontracts; prol'ided, that the Government's payments to the Contractor shall
not exceed 85 percent of the allowable costs of those subcontractors.
c. Eighty-five percent of all other approved costs (See Paragraph (E)(2)).
2. Limitation of reimbursement: To determine 1he amounts payable to !he Contractor
under this change order, the Contracting Officer shall determine allowable costs in
accordance with the applicable cost principles in Part 31 of the Federal Acquisition
Regulation (FAR). The total reimbursement made under this paragraph shall not
exceed 85 percent of the maximum amount of the Government's liability, as stated in
this modification.
3. Invoicing: Payments shall be made promptly to the Contractor when requested as
work progresses, but (except for small business conccms) not more often than every
4 weeks. in amounts approved by the Contrm:ting Officer. The Contractor may submit
to an authorized representative of the Contracting Officer, in such fonn and
reasonable detail as the representative may require, an invoice or voucher supported
by a statement of the claimed allowable cost incurred by the Contractor in the
perfonnance of this modification.
4. Allowable costs: For the purpose of determining allowable costs. the term "costs"
includes;
a. Those recorded costs that result. at the time of the request for reunbursement,
from payment by cash. check, or other form of actual payment for items or
services purchased directly for the modification;
b. Wl1en the Contrador i.s not delinquent in payment of costs of contract
perfonnance in the ordinary course of business. costs incurred. but not necessarily
paid, for:
l. Supplies and services purchased directly for the contract and
associated financing payments to subcontractors, provided
payments determined due will be made:
1. In accordance with the tenns and conditiorn, of a
subcontract or invoice; and
11. Ordinarily within JO days of the submission of the
Contractor's payment request (o the Government:
Page 2 of 3
Attachmcnl A: Modificalion Description
Modification 0020
ED-FSA-09-D-0014 (PHEAA)
111. Matcriab issued from the Contractor's stores inventory

and placed in the production process for use on the
contract;
iv. Direct labor;
v. Direct travel;
v1. Other direct in-house costs; and
v11. Properly allocable and allowable indirect costs a.s
sho\vn on the records maintained by the Contractor for
purposes of obtaining reimbursement under
Government contracts; and
c. The amount of financing payments that the Contractor has paid by cash. check. or
other forms of payment to subcontractors.
5. Audit At any time before final payment. the Contracting Officer may have the
Contractor's invoices or vouchers and statements of costs audited. Any payment may
be:
a. Reduced by any amounts found by the Contracting Officer not to constitute
allowable costs; or
b. Adjusted for overpayments or underpayments made on preceding invoices or
vouchers.
Page3of3
ATTACHMENT B
New Consolidation Initiative (Deliberative Draft)
1. NSLDSsends COD list of eligible borrowers and the TIVAS associated with that borrower.
2. SL.GOV(COD) build PNOTEcollect data from the student. (student is deemed eligible based on
NSLDSlist)
3. COD will use the Real time MQ Series Consolidation Loan Data feed from NSLDSto request loans
and pertinent information on the borrowers.
4. COD will assign an unique MPN ID.
S. TIVASwill be provided MPN ID and PNOTEwith the loan data to complete the LVC
6. TIVASwill create new consolidation loans. (one for each underlying loan) that take on some
characteristics of the underlying loans (interest rates, repayment terms, payments made to
date, rebate and interest programs) However new loans will have new loan dates,
disbursement dates, DERs,etc.
7. TIVAS use LVCto payoff underlying loans (similar to purchase program)
8. The New Consolidation Loans will be DS (direct loan consolidation unsub), D6 (direct loan
consolidation sub), and D7 (direct loan plus consolidation) -(Maybe a good time to determine if
we need a separate Grad Plus consol loan type)
9. The TIVASwill report all new loans on this PNOTEwith the same MPN ID (this will link them)
10. The TIVASwill use a new OPEID on the new loans (provided by ED)
11. The underlying loans will be Paid thru consolidation per normal procedures.
NSLDSProgramming Changes
1. Create list of borrowers for COD on a weekly basis, with one large cumulative file and changes
only following.
2. Update the Real Time MO Series Consolidation loan transfer
3. Test with COD
4. NSLDSwill create a process of using MPN ID to join these loans efficiently
S. NSLDSwill use the FMS program code in TIVAS file to create a new lender id to distinguish these
loans. (FMS and FPDM will also create new lender ID)
6. Accept the loan OPEID (May affect other systems FPDM, CPS,etc ....look into further)
7. Create standard reports for management
Assumptions:
1.No change to CDR or GE calc

2. No change to LOE
3. This will break out loans in the programs similar to loan purchases for reporting
·New Consolidation Loan Program Process Flow - Deliberative Draft Attachment C
------- ----
I
! /~- '
(\'- Start )
en
g ,-··-· _____t_
I
I -i -- --
- -----·-
en
z
Creates List ot '' r Creates New
consohdat1on
I
:
IE11g1bleBorrowers •
and Sends to :/OD:
1.Res~:~a s ! f
loans with
1 previous
relevant
TIVAS, COD loan data J
L -f -
C--" --
i --t-- ---+·--·
~
'1
·
-·-- __ ,
Creates
···-·
1 1------7
0 , Consolldat1on , ' !
0 ~ Loan on SL.gov : Sends application !I
(.) ------,.. data to TIVAS

1and performs "data I
I t_~11··with NS_LDS~
!
I i-
~- ·----------:---1:-_---· ----=-~y_·_ . ;
i --· ~----
!
----
en I 1,
1· Market Loan •1
i t
I,Re•l,ewsdata and ;
I
i. Creates new DL
IConsolidationloan
I '
~ i requests LVCIEAI · Create payoff file
---1 Ser111ces
new
l._ __
- ---~ Consol1dat1oto
n
27 file from . and reports to loans
j:: · Borrowers
I
1
L•.-------
lenders
for FSA
l--.---~'NSLOS
'L---~~
~
1
----- 'f --
_j_ -·- -------+- --- -- T I
I -7 I
!.,~;:,I ► ·,
'! Borrower I
I
'. -
0
0
CD
completes loan
app on SL gov
'
Joan(s)
oew
I Stop
______
_,
L__
'
' _____ -J I
I
I
::!,:,;;;-1
-- --- -· - --1 ---
I!!
1
' - - -C,mpl,t~
- ,--~.:: I
f
.3
-- -- .___.,,
or similar file for
TIVAS
I
'
1 "Paid through .
Consolidation" to '
NSLOS (through
GA)
-- --- J_ -----e
en
-•
::;; Pay lenders under- i
LL : new program eode I · --
l
-
1 Contrac1 ID Code __
_P_a_g_e
of Pages_
1 8
2. AMENDMENT MODIFICATION NO. 3 EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ. NO 5 PROJECT NO (if applicable)
020 SEP 23. 2011 EDOFSA- 11-001074

6 ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other than ,tern 6) CODE
Uo,ted State:; Depa~meol of Educat,011
Fed e,a IS lU d <!0 !Ad/M ,ss,on Support G roup See Block 6
' 91 F3
630 First S: NE - Su,te
Washington DC 20202
Julia Jones
! 8 NAME AND ADDRESS OF CONTRACTOR (NO, Street. Country, Slate and ZIP Code) 9A AMENDMENT OF SOLICITATION NO
PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY DUNS: 007368103 (,) I
~
HARRISBURG PA 171021444 96 DATED(SEE ITEM 11) '
'i
10A MODIFICATION OF CONTRACT/ORDER NO I
EO-FSA-D9--0-0014
X
I FACILITY COOE '
CODE 0003077 4 JUN 17, 2009 I
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS I
I D The above numbered solicitation is amended as s_eiforth in ,tern 14. The hour and date spec_ified_rorreceipt of offers D is extended, Dis not extended. !
Offers must acknowledge receipt of lh1samendmenl pnor to lhe hour and date specified m the sol1c1tatIonor as amended, by one of the following methods
(a) By comple1ing items 8 and 15, and returning ___ copies of amendment: (b) By acknowledging receipt of this amendment on each copy of the offer submitted:
or (c) By separa!e letter or telegram which includes a reference to lhe so!icita\1onand amendment numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF
1 YOUR OFFER If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter. provided each
tele ram or lel\er makes reference to lhe solicitation and this amendment. and is received rior to the o enin hour and dates ecified.
12 ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: 100,000 00
See Schedule Modification Obligated Amount: $100,000 ooi
I 13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER ID ISSUED PURSUANT TO (Spedfy authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
e-----~ ORDER NO IN ITEM 10A
I
I X 52.212-4
i
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes In paying
i office. appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b)
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF.

I
i
D. OTHER (Specify type of modification and authority)
E. IMPORTANT: Contractor Ix is not. I is required to sign this document and return copies to the issuing office.
I 14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including sohcitat1onlcon!ractsubject malter where feasible)
i
Except ~s ~rov•de<l Mre,n. all lerms and cond,tK~•s of lh~ ~<J,.umer.l ,~Je,.,~cffi ,n ,tern gA or 10A. ~s herPlolore ch~nged, remains unctianged and ,n full force dM effect
1SA NAME AND TITLE OF SIGNER (Type or pnnt) 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
; Nicholas Chung
=202-377-3635 nichotas chung@ed gov
--~----..7J~, 0,•c'.
-,.15"-'3'c'(;"_O"t<_"T"R~A"C~T"<)'_"l=Q,F'F'E"R'0°R~-.-::::::::-_-
"D"A'T"E"s·,c"N"E"0"'"'''6B~U~N.ITED ~'6"C~D"A'T'E's•,·c·N'E'D~---
STA-ffif""oFA'"M'E"R',"C"A--._-_-1'. ~1
I (b)(6)
SEP 23, 2011
(Signature of person authorized to sign) S, nature onlr.:ictin Officer

!\SN 75-IO"Ol-15~-8070 ST.\ ....DARD H)R'\-1 JO. (Rev. 10-SJ)
Prnwus Ed111onunusuhlc l're~rnheJ by GS:\ FAR 14X(TH) 53 ~-1.1
OBTAINED BY STUDENT BORROWER PROTECTION CENTER ANDSupplementary
AMERICAN FEDERATION
Page OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
See Attachment A for Modification Description.
PAGE 2 OF 3 ED-FSA-09-D-0014/020
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION
SCHEDULE Continued OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT -7
ITEM NO. SUPPUES/SERVICES
---!---------------+----+---+------+-----
QUANTITY UNIT > UNIT PRICE S ·~---.-.-0,-,-
1
! I
'I (New Line Item)
0014
Funding for Loan Consohdation Initiative. 1.001
i SE 100,000.00 100,000.00

:0202A2011 B 2011 ENB00000.6CA.2521A.AAJ 000 0000 000000
1
$100,000 00
FOB Destination
'
' '
l__________
_l________________
-----
PAGE 3 OF 3 ED-FSA-09-D-0014/020
Attachment A: Modifical1on Description
Modifirntion 0020
ED-FSA-09-D-0014 iPHEAA)
The purpose of this modification is lo issue a Change Order pursuant to 1he Changes Clause
52.212-4, section 8.1 (C) of the base IDIQ contract for the following:
A. Direct Loan Consolidation Initiative and Process Flow

I. The contractor is directed to begin work on this requirement as of September 23,
2011 in accordance with the attached requirements document (,\lta<.:hments Band C). as
applicable.
2. The definitive contract modification resulting from this change order will include a
negotiated finn fixed price in no event to exceed$ I 00,000.00.
The following tenns and conditions apply to both requirements above:

A. The Contractor shall begin promptly negotiating with the Contracting Officer the tenns of
a definitive contract modification that will include all clauses required by law on the date
of issuance for the modification, and any other mutually agreeable clauses, terms, and
conditions.
B. Dcfinitization Schedule:
1. Date for submission of the revised proposal with cost & pricing data and updated
subcontracting plan: October 6, 2011.
2. Planned Date of the stat1 of negotiations: October 12,201 I.
3. Planned Target date of definitization: October 26. 20 I I.
4. Date for submission of certificate for ce11ifiedcost & pricing data: One business day
after final negotiation.
C. The Contractor shall provide cost and pricing data in accordance with FAR 15.408, Table
15-2 supporting its proposal for the following:
I. Actual incurred costs through date of definitization of lhis change order.
2. Work yet to be completed through completion of project.
D. If agreement on a definitive contract modification to supersede this change order is not

reached by the target date in paragraph (B) of this section, or within any extension of it
granted by the Contracting Officer. the Contracting Officer may determine a reasonable
price or fee in accordance with Subpart 15.4 and Part 3 I of the FAR. subject to
Contractor appeal as provided in the Disputes clause. In any event. the Contraclor shall
proceed with completion of the change order, subjecl only to the Limitation of
Government Liability clause.
I. After the Contracting Officer's determination of price or fee, the contract modification
shall be governed by:
a. All clauses required by law as of the date of the Contracting Officer's
detennination; and
b. Any other clauses, terms, and conditions mutually agreed upon.
Page 1 of 3
Attachmcnl A: Modification Description
Modification 0020
ED-FSA-09-O-0014 (PflEAA)
2. To the extent consistent with paragraph (D)( I) of this section, all clauses. terms, and
conditions mdudcd in this change order shall continue in effect.
E. Payments of Allowable Costs Before Definitization

I. Reimbursement rate: Pending the definitization of the change order referred to herein,
the Government will promptly reimburse the Contractor for all allowable costs under
this contract modification at the following rates:
a. One hundred percent of approved costs representing financing payments to
subcontractors under fixed-price subcontracts, provided that the Government's
payments to the Contractor will not exceed 80 percent of the allowable costs of
those subcontractors.
b. One hundred percent of approved costs representing cost-reimbursement
subcontracts; provided, that the Government's payments to the Contractor shall
not exceed 85 percent of the allowable costs of those subcontractors.
c. Eighty-five percent of all other approved costs (See Paragraph (E)(2)).
2. Limitation of reimbursement: To determine the amounts payable to the Contractor
under this change order, the Contracting Officer :-.halldetermine allowable costs in
accordance with the applicable cost principles in Part 31 of the Federal Acquisition
Regulation (FAR). The total reimbursement made under lhis paragraph shall not
exceed 85 percent of the maximum amount of the Government's liability, as stated in
this modification.
3. Invoicing: Payments shall he made promptly to the Contractor when requested as
work progresses, buL(except for small business concems) not more often than every
4 weeks, in amounts approved by the Contracting Offo:er. The Contractor may submit
to an authorized representative of the Contracting Officer, in such form and
reasonable detail as the representative may require, an invoice or voucher supported
by a statement of the claimed allowable cost incurred by the Contractor in the
performance of this modification.
4. Allowable costs: For the purpose of determining allowable costs, the tenn "costs"
includes:
a. Those recorded costs that result, at the time of the request for reimbursement,
from payment by c.:ish, check. or orher fonn of actual payment for items or
:,;ervicespurchased directly for the modification;
b. When the Contractor is not delinquent in payment of costs of contract
performance in the ordinary course of business. costs incurred, but not necessarily
paid, for:
I. Supplies and services purchased directly for the contract and
associated financing payments to subcontractors, provided
payments determined due will be made:
1. In accordance with the terms and conditions of a
subcontract or invoice; and
ii. Ordinarily within 30 days of the submission of the
Contractor's payment request to the Government:
Page 2 of 3
Attachment A: tv1odific.ilion Description
Modification 0020
ED-FSA-09-D-0014 (PHEAA)
111. Materials issued from the Contractor" s stores inventory

and placed in the production proccs-; for use on the
contract:
iv. Direct labor:
v. Direct I ravel:
v1. Other direct in-house costs: and
v11. Properly allocable and allowable indirect costs as
shown on the records maintained by the Contractor for
purposes of obtaining reimbursement under
Government contracts; and
c. The amount of financing payments that the Contractor has paid by cash, check, or
other fom1s of payment to subcontractors.
5. Audit: At any time before final payment, the Contracting Officer may have the
Contractor's invoices or vouchers and statements of costs audited. Any payment may
be:
a. Reduced by any amounts found hy the Contracting Officer not to constitute
allowable costs; or
b. Adjusted for overpayments or underpayments made on preceding invoices or
vouchers.
Page 3 of 3
ATTACHMENT B
New Consolidation Initiative (Deliberative Draft)
L NSLDSsends COD list of eligible borrowers and the TIVAS assodated with that borrower.
2. SL.GOV(COD) build PNOTEcollect data from the student. (student is deemed eligible based on
NSLDSlist)
3. COD will use the Real time MQ Series Consolidation Loan Data feed from NSLDSto request loans
and pertinent information on the borrowers.
4. COD will assign an unique MPN ID.
S. TIVAS will be provided MPN ID and PNOTEwith the loan data to complete the LVC
6. TIVAS will create new consolidation loans. {one for each underlying loan) that take on some
characteristics of the underlying loans (interest rates, repayment terms, payments made to
date, rebate and interest programs) However new loans will have new Joan dates,
disbursement dates, DERs,etc.
7. TIVAS use LVCto payoff underlying loans (similar to purchase program)
8. The New Consolidation loans will be OS (direct loan consolidation unsub), 06 (direct loan
consolidation sub), and D7 (direct loan plus consolidation) -(Maybe a good time to determine if
we need a separate Grad Plus consol loan type)
9. The TIVAS will report all new loans on this PNOTEwith the same MPN ID (this will link them)
10. The TIVASwill use a new OPEID on the new loans (provided by ED)
11. The underlying loans will be Paid thru consolidation per normal procedures.
NSLDSProgramming Changes
1. Create list of borrowers for COOon a weekly basis, with one large cumulative file and changes
only following.
2. Update the Real Time MQSeries Consolidation loan transfer
3. Test with COD
4. NSLDSwill create a process of using MPN ID to join these loans efficiently
5. NSLDSwill use the FMS program code in TIVAS file to create a new lender id to distinguish these
loans. (FMS and FPDM will also create new lender ID)
6. Accept the loan OPEID (May affect other systems FPOM, CPS,etc. ...look into further)
7. Create standard reports for management
Assumptions:
1. No change to CDR or GE calc

2. No change to LOE
3. This will break out loans in the programs similar to loan purchases for reporting
INew Consolid ation BY
OBTAINED Loan Program
STUDENT Process
BORROWER PROTECTION CENTER
Flow - AND AMERICAN
Deliberat FEDERATION
ive Draft OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
Attachme nt C
e--- ------j'
i i
------------
(
(/J i
~ l -----.
i--C;e-~~Li st:; ·-·-··7 I ~~:~--!,~~i~
;I
Z
II
i Eligible Borrowers
and Sends to
TlVAS.COD i
__ _
'
I
Responds to ·coo 1
Data calf
___
·-!--
'
Ji I 1loans with
previous relevant
---7------
---- -r ----
loan data
-- -- --------i
,--- --- '

Q
0
:
·
Consoildat1on
Loao oo SLgo,
:
I
____
_J Sends application !
(.) and performs "data i, : data to TIVAS I
call" with NSLOS
---+-
,---
Market Loan
,····· ---'----
1 Reviews data and ,
--,~
_l-_-I l
Creates new DL
·-;c '- - - _T_--
j -.
-- ..- Consolidation to I requests LVC/EA i Create payoff file Consolidationloan : Services new
-----►,
Borrowers I 27 fi!e from i for FSA and reports to I loans

. le~ers _J NSLDS
------+-----
r·-- -•--
..
--l-
-
Q)
;, Borrower
t._ --,
-0
0
completes loan
app on SL.gov
ce1vesnew
loan(s)
'I
i
"'
➔-
__J
-,---- -~r-=t-:--=--:--~------ --
,,-
"' , : -Repori;~a~~
Q)
L. ---- --·
' Completes EA 27 :
~ or similar file for i
·
i "Paid through i
C:
Q)
...J
I
l
; TIVAS
L _____ ~
I
----;-•--
1t ~~~~~d(~~l~~gl~
~---~-"
--···--
GA)
--------- ------- ·-·

- --- ,j, ---- -
(/J
:::;; Pay Lenders uncle( ___ j
u. , newprogramcode _
1 Contract 10 Cod\!
l. AMENDMENT MODIFICATION NO 3 EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO. j 5 PROJECT NO
022 NOV 15. 2011

6 ISSUED BY CODE FSA-fS2 7 ADMINISTERED 8Y (If othar lllan ,tern 6) CODE
U!111"'1 $1RIOS Oeµartrnenl ul Edur.-llbO<l
Fo<l,,ral SIUdont /\.:!1M•'5,or, Sow,:,rt Gn:,•,p See Block 6
I 8'.JOF;rsiSINE-S.,,t,.9!F:l
I Wash,n~ton DC 20202
Jul"' Jones
8. NAME AND ADDRESS OF CONTRACTOR (NO. Stroot. Coun!ry, Slate and ZIP Cod&)
I 9A. AMENDMENT OF SOLICITATION NO.
i
(,)
PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY DUNS: 007368103
~ i
HAAR!S8URG PA 171021444 98 DATEO(SEEITEM 11)
IOA. MODIFICATION OF CONTRACTIORDER NO.

EO-FSA-C9-0-0014
X
CODE 00030774 I FACILITYCODE JUN 17, 2009
D The abo~a numbefOO solici!a1lon is amended as set forth in i1em 14. The hour and dale specified (or 1eceipl of offers is exlendoo, Dis O
no4 extaodad.
Offers must acknowledge rece,p« of this amendment prior to the hour and date specified m lha sollcdat,on or as amended, by one of lhe following malhods.
(a) By completing ,tams 6 and 15, and re1um,ng __ oopies of ameodman1; (b) By acknowladgir,g mc6ipl of lhis ,amendm6nl on each copy ol lhe offer submitted:
or (c) By separate latter Of telegram which in dudes a reference to the solicitation ,md amandmeol numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE OE SIG NA TEO FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR ANO DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER II by 111rtua of lh,s amendment yoor desire to chang6 an orfer already submitted, such change may be made by telegram or letter. provided each
tal...,ram or lallar makes reference to Iha soHcitation and lhis amendment, and Is received orlor lo the o n,nn hoor and dale snecIfiad.
12 ACCOUNTING ANO APPROPRIATION DATA (If raquired) Modification Amount: ..-v.00
Modificalion Obligated Amount: $0.00
See Schedule
Check One A THIS ORDER ID ISSUED PURSUANT TO· (Specify aulhori1y) THE CHANGES SET FORTH IN ITEM 14 AAE MADE IN THE CONTRACT
ORDER NO IN ITEM 10A.
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changas in paying
office, appropnalion date. e!c) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103(0).
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF·
X FAR clause 52.212-4 Contract Terms and Conditions
D. OTHER iSpec,fy lype of modir.calron and au1hofity)
'
E. IMPORTANT: ContJacto, I is not. Jx is required to sign !his document and return _____J____copies to the issuing office.
14. DESCRIPTION OF AMENDMENT:MODIFICATION (Organirnd by UCF section headings, lodidmg sol1cila!iooicon1ract subject mailer wtiere feasible)
f.•<.efJIa• pros,dO<l"""""· a~'""'" a.-.:l'-"""'"""" ol tho d<l<:umMIre'"'""""" ,n ,1..,.,9A ,~ 10A. as ,,.,,.o«,!o,.,

U>angod romat,,5 ~nchango<l aM In ft,o !on;,,
at'<!off&ct
15A. NAME ANO TITLE g_f
SIGNER (Typa or prin1) 16A NAME ANO TITIE OF CONTRACTING OFFICER (Typ,;,01 p<inl)
fT):dth?· \,I__) D ~:i~• ,' MikamikeWhisla,
whisler@ed gov ,I~
\ /'\J-,H7-r.ffiYV\ l'i ,eL,t)C+ulIcr.,,<..ont,r

,ni ,1
~ 15C, DATE SIGNEfl l6C DATE SIGNF.D
~- (:_ON_T Cf 'OFFEROR '-168 UNITEOSTATE~_QF1AMERICA
'
! r)(6) I : ,i_ (b)(6)
: N0?-2011
'<'..
(S,gnalurn of person aultionzad to sigri)

.~vJl,c)ilI I !
/Sinnalu,e ol Con!ractInn Officer\
' .
NSN 7540-0! .152.3010 STANDARD FORM J@, (Rev. HI-SJ)
Prcv,ous Edition unusable Prescnbc<l hy GSA F,\R (48 CFR) 51.14.1
Supplementary Page
The purpose of this modification is to incorporate the following Task Order 0005 documents into the contract
for Public Service Loan Forgiveness - Single Servicer.
1. Attachment A - Terms and Conditions (2 pages)
2. Attachment B - Public Service Loan Forgiveness - Single Servicer Requirements V1 .0. (26 pages)
a. Appendix A (PSLF Employment Certification Package)
b. Appendix 8 (Instructions for Reviewing an Employment Certification Form for PSLF).
c. Appendix C (Sample PSLF Report).
PAGE 2 OF ED-FSA-09-0-00141022
Attachment A- Terms and Conditions Pagelof2

Public Service Loan Forgiveness - Single Servicer
Contract No. ED-FSA-og...0.0014, Task Order 0005
Terms and Conditions
Objective:
The servicer shall enable borrowers to track qualifying payments and employment, using the Employment
Certification form, while in the process of qualifying for Public Service Loan Forgiveness in accordance
with the Public Service Loan Forgiveness Single Servicer Requirements v.1.
Pricing:
The following provides the pricing on a per borrower basis for each approved/denied Employment
Certification Form (ECF).
Implementation/ Unit Price Per Unit Price Per

Servicer Development Cost ECF Approved ECF Denied
PHEAA
b)(4)
I j(b)(4) I j(b)(4) I
• Unit Price per ECF Approved: A borrower with a valid ECF (complete, signed and dated,
certified by authorized official from validated qualifying public service organization) and transfer
completed (loaded on system). (Invoicing may occur upon completion of the transfer.)
• Unit Price per ECF Denied: A borrower with an incomplete ECF or request does not support
PSLF qualifying employment. The PSLF servicer would communicate with the borrower to obtain
a valid ECF, but loans not requested to be transferred. (Invoicing may occur after the PSLF
Servicer has notified the borrower of the denial.)
• PSLF Servicer may only bill the Government once per unit (Approval or Denial), per SSN. See
the following examples:
• A borrower submits an approved ECF. The PSLF Servicer may bill the Government once
for the approved ECF, regardless of any re-certifications required during borrower
tracking within the program and payoff at completion.
• A borrower submits a denied ECF, then submits an approved ECF. The PSLF Servicer
may bill once for the denied ECF, then again for the approved ECF.
• A borrower submits three consecutively denied ECFs, then on the fourth attempt, the
ECF is approved. The PSLF Servicer may only bill for the first denied ECF, then once for
the approved ECF.
• Once an approved PSLF borrower is transrerred on system, the current servicing pricing terms in
the TIVAS agreements shall apply.
• The PSLF Servicer shall maintain and provide FSA with a record that will enable FSA to validate
the units invoice per billing period. This may include a roster of borrowers that have been both
approved and denied, the corresponding dates, and if denied, a reason for the denial (e.g.
incomplete ECF or request does not support PSLF qualifying employment).
PAGE3 OF E0- FSA-09-0-0014/02 2
Attachment A- Terms and Conditions Page2of2
Schedule:
The implementation date is schedule is for January 31, 2012.
Disincentives:
The following disincentive is incorporated into this contract to ensure Federal Student Aid {FSA)
performance objectives for the PSLF requirements are achieved by the required implementation deadline:
The contractor shall complete implementation of all requirements by the implementation deadline listed
above. For every calendar day that full implementation is not achieved, FSA will reduce the contractor's
initial invoice payable amount by 2% per day tale. Should delays extend beyond a reasonable period,
FSA may continue to reduce the payment amounts of subsequent invoices, or take other actions as
appropriate in accordance with the tem,s of the contractor's base contract.
FSA approval of the Validation Artifacts is necessary for any requirement to be considered completed.
However, for the purposes of calculating this disincentive only, the date of acceptance will be
considered as the date that the accepted validation artifact was submitted to FSA for approval.
Additional Terms and Conditions:

1 Unless otherwise stated, all other terms and conditions of the Base Contract are applicable and
incorporated herein.
2. Public Service Loan Forgiveness Single Servicer Requirements v .1.
PAGE 4 OF ED-FSA-09-D-0014/0 22
~Haclwn"'1t6 - PSLF 5,ngl~ s~,..,,,..e, R.,.,u~e,n,;n"' Pag,o 1 ol 26

Eo.fSA-r"R-0-001~. Ta•~ cm"' !)0()5
P~M,)"v&nl• H'<)M• £<1<,talM AA,,Sla"°'e Al)&r>(>J
!PHFM)
Public Service Loan Forgiveness - Single Servicer

Requirements
V1.0
Purpose:
The College Cost Reduction ond Access Act (CCRAA) of 2007 created a new loan forgiveness pro,grnm for Oirec1 Loan
bom,we,s who make 120 paym .. nts. These payments must be made alter Oc!ober 1, 2007 and the borrower must be
employad in c.,rt,i;n publfC ~ervice JObs.as dMtned in the regulallons, during the time tne payments a,e made and at the
time forgiveness ,s ,equested and granted Once the Department determ,nes whelher all of the requiremenls for eligibility
have been fum~ed. the balance of prmapal and interns! due on lh!J t,orrowMs eligible Drroct Loans shall be forgiven.
The purpose of this effor1 is lo rmplement a PSLF servicer to enable borrowers to track qualifying payments and
empjoymcnt, usmg the Employment Certlfica1,on form. while In the process of qualrfylng for PSLF Ally borrower who 1s
dedarn<l on-track for PSLF wilt be transferred to the PSLF seniicer. wllo w,ll process all fonns aod handle all
comrnunicaLions regarding PSlF, as well as perform all non-PSLF related servlc,ng lunc~ons on a bom;,wer portfolio, as
required of all federal ~an serncers. PSLF summary !racking ,nfonnatlon w,11be reported by lhe PSLF servicer to NSLDS
for pull)oses of data cotle.:lion rnlatlng lo lmplemefltation of forthcoming gainful employment regulations
This requires the PSLF servicer to t>e able to:

Collect, review and retain lhe submitled elfl)loyrnent cer1ificatlons:
Receive all ellglble loafls and provlda comprehensive seivlclng of all federally heM loans to borrowers who may or
may no! ultlmately be eligible for fo~iveness based on public seniice.
Detemuna lhat !he bormwer has made qualifymg pa~nls while employed ,n qualifying public ser,ice:
Track PSLF ellg,bllity sla!us for the on-track borrower; and
Report 1rartlng information to NSLDS.
For the purpose of these raqu,remenls, lhe numbetir,g sequences are as follows:
200 - PSLF Single Servicer requlremenls
R··• R u,rement Validation Artifact

200 00 The PSLf servicer shall provide the Employment Certification package (to Commilmen1
be provided by FSA), which includes the Dear Borrower Lettet', statement
Instructions for Completlng the Employment Certlflc.atlon, and the
Employment Certification for Publk SeNlce Loan Forgiveness, to the
Employment Certiflcatlon package.
200 01 The Public Service Loan Forgiveness Program Employment Certification Procedure
package and other mformation (e g., PSlF Fact Sheet) shall be provided on
borrower request,
200.02 The provision of the Public Service lo<1n Forgiveness Program Employment Screen shots of
Certification padage and information shall be recorded In the account
borrower's/recipient's correspondence and account history rt'Cords.
~---
201 00 The PSlf se!Vlcer shall collect the Employment Certification form, Procedure 10<
conduct an Initial review, and retain the ECFfor the borrower. completing initial
review
--- ---
201 U1
----
The irntlal rev,ew shall check that the borrower provided JII required Procedu•er tor
information on the submitted form. If the form is de!erm/ned to be collec1.Jfl!Imissing
,nfonna1l0'1 and
incomplete, the PSLFservicer sh<1IIcommunicate with the borrower and
sa--1-e oobijca\lon
·--~--
PAGE 5 OF ED·FSA-09·0-0014/022
A~JJCm"on!8 - PSI.F $,ngJg Sornc.o, Reqvum""t, P"')lt2o!26

ro-rsA-00-0.oou.
r.,1,;o,_ ooos
Ponnsitv.,-.o H,yh,r Educ.aOOfl/\ss•star>e11
Aguo'q- 1Pl-1EAA)
coll,-ct the mi,s;ng 1nformat1on.
201 02 Retention of the original form requir,-s malntaining an imaged copy of the Procedure
original on 1he PSLF.ervicl;'r's 1y>tem until lhe O,:,partment grants
forgiveness for the borrower.
202.00 The PStF o;e,vker shall determine whether an employer Is a qualifying Comm,tmoot
public seovl,e 0<1an1,atton, ba$ed on the submitted Employment sti>lement
Certlfkat!on fo,-m.
202 01 The PSlf servicer sh.JI!follow procedures for val1datmg quahfymg pubhc Provide proc&dure
service, according to a validation process approved by FSA. which will
Also provide
includes looking up employers in searchable daiabases, based on the-type examjlles of 1est
of public service organization. See Appendix B-(Oraft) Instructions for bom:iwers for whom
VaIi dating a Qualifying Publk Service Organization th() PSLF se,vlcer
completed valldation
ofECF~.
202.02 The PSLFservicer shall e.calate to FSAcases for whoch a public service Proceoore.
organiiatlon cannot be determined to be qualifying or non-qualifying,
based on the provided validation process.
' 202 03 The PSLFservicer shall determine whether the borrower h<1smet the full- Proc00u"3.
time requirement, as provided in the regulations, while employed by the
qualifying putlllc service organization, based on the hou~ indicated on one
or more certifications.
202,04 The PSLf servicer shall have the abillty to override Judgment of pub lie Procedure.
service employers, per FSAauthorization and on an exceptmn basls, to
make them qualifying or not qualifying employers for the- Public Service
Lodn Forsiveness Program. The PSLF~ervicer ,hall note the FSA-
au1horized condition on the borrower account.
203.00 The PSLFservicer shall request the transfer of all federalfV-held loans IBD
(lndudlng PSLF-ellglble Direct Loans and PUT loans) and
account/servicing hl$10l'Vflies from the borrower's original serv!cerfs),
once a valid ECFIs processed {see Requirement 202).
204,00 The PSlf servicer ,hall determine lf PSLFqualifying payment1 were made Procedure for
on ellglbfe loans, and track the number of PSLFqualifying payments detennining PSLF
made after the loans are transferred from the original servicer.
Screen shot of test
IJOnuwar'Mth
qualifying paymen1
lrac~ing record,
pos\-!ransfef to
PSLF s"""icer
204 01
AU Direct Loan Program loan type5 shall be included in the payment
tracking for the Public Service Loan Forglvenes~ Progr~m-
204 ~l
The PSLFservicer shall consider payments made after October l, 2007
while the borrower is on the follow,nl!'. e!i 1ble repayment pfans. for
PAGE 6 OF ED-FSA-09-0-0014/022
Allact,mar~ 6 - PSLF C"•>;1leSeo"""'' RQQo1'.,.,,.,"t,,

ED-FSA--09-0-0014 Taslo O,<M,0005
P•ru•"Y'••'"· HO(JM•E<l~<-o- A,;o/s""1c• Age<'C\I1PHEM)
I trading purpose for the Pi,blic ServKe loan Forgiveness Program:
,. The Income-Based Repayment (JBR!plan:

I
i i'
ii. The lncorne Contingent Repayment (KR) plan;
!
I
I iii. The Standard Repayment plan b.J~ed on a 10-year repayment term
' (note that p.1yments made on the Standard Repayment Plan for
! Direct Co11solidationLoans only count as quaUfymgpJyments for
PSLF1fthe term does not exceed 10 years); and
iv. Any repayment plan other than IBRand KR where the monthly
installment is equal to or grf>aler than the Standard Repayment
plan based on a 10-year repayment term.
204 03
Borrowers mu,t make 120 separate on-time qualifying payments after
October 1, 2007 to be e!1g1blefor the Public Service Loan Forgiveness
Program
,. All 120 payments must be made after October 1, 2007 to be

ehgib!e for the Public Service Loan Forgiveness Program.
ii. For the Public Service Loan Forgiveness Program, payments shall
be comidered on-time when they are received no later than lS
days after the scheduled payment date.
iii. For the Public Service Loan Forgiveness Program, a qualifying

payment must satisfy the full current payment due Jrnount for
that month.
iv. Borrower prepayments (payme11tamounts equal to or more than

one full monthly payment amount) shall only count as one on-time
payme11t when tracking for qualifying payments for the Public
Service Loan Forgiveness Progr.m.
~04.04 Scre,;,11shol ol test

Payments made while the borrower 1sman m•school, rn-grace, deferment, borrowers showing
qualifyingpayment
forbe~rance or a suspended activity status shall 1101be included as
not applied due to
qualifying payments for the Public Service Loan Forgiveness Program. non·,.,payment
status.
204.05 ~ - ScrMn shot of test
Payments made on a loan while it 1sm a default status shall r10tbe t>orrowersshowing
included as qualifying payments for the Public Service Loan Forgiveness ~ualifyillgpayment
no\ applied due to
Program. This indudes payment, made as part of a rehabililat,on default status.
agreement on a defaulted loan.
For purposes of determining qualifying payments for the Public

'! ' Service loan Forgiveness Program. default status means greater
L_ than 270 day~ dPlmqoent
PAGE 7 OF ED-FSA-09-0-001411l22
~uoc/-.m""t
B- PSLF Sn11jle,
S.,n,,c,;rRoqu"""'""~
fD.FSA-O<l-0-0014 Task O<dO<0005
PMHS)l,,.,,a 1-'tgr- Eoucaboo /ls,.slanc9 Agoncy (PHfM)
I 204 06 Pror.edure for

I A lump sum payment made by AmeriCorps votunteer1 using all or part of a app1y,ngthe
Amer,Corps/Peece
Segal Education Award or Peace Corps volunteers u~ing all or part of a
Corps excep1ionfor
Peace Corps tr.insit1on payment shall be consider~d to hdVe made up to !ump ,um payments
twelve qu;;ilifying payments per borrower, as allowed In the regulations. 10 oe considered
!
..___________
___ qualifying for PSLF.
--------
204 o, ~
- ----
Screen shot of test
The PSLFservicer shall track a borrower's ex peeled eligibility date for the borrower w~h
Public Service loan forgiveness Program. expeclad ohg1bdlty
date adjustmoots
due 1onon-
The e~pected ellgibdity date shall adjust due to periods of non-
' repayment (induding periods of In-school, in-grace, defermenl,
qual1fy1ngpayments
forbearance, and suspense st.it us) and non-qu,illfying payment

(including delinquency and paym...nts made that are less than the
current full scheduled payment amount).
204.06
' The PSLFservicer shall have the ablllty to override
payments, per FSA Procedure
authorization ,ind on an exception basis, to make them qualifying or not
qualifying payments for the Public Service Loan Forgiveness Program. The
PSLFservicer shall note the fSA•authorlzed condition on the borrower
,1ccount.
205.00 The PSLFservice.- shall match quaHfylng paymenn; that were made Comrrotment
during the periods Indicated on the Employment Certifications. statement.
205.01 The PSLFservicer shall determine 1rthe qualifying payments were made Prow:le procedure
while in qualifying employment. for matching
qualifying payments
with quai,fying
L Count each month from the Start Date to End Oate (Section 3 Item
employment
2a of ECF). for which a quallfylng payment w,1s made. For the fir-st
month, the actual payment date must be on or after the Start Al,io provide
Date. For the last month, the actual payment date must be before examples of test
the End Date last month of each Employment Certification. For borrowers for which
qua.tif1ingpaymen1s
Part-lime employees, these conditioM apply to each employer. and employment
have t,een matched
ii. For p,irtlal payments made, the actual payment date is the date on
whkh the total of p,irti,il payments equ,ils to or is greater than the
full scheduled payment due amount for that month.
iii. The scheduled payment datl' will determine the calendar month
for wh,ch the ciualifylng payment Is counted.
Example: Scheduled payment date ,s July 1 but actual payment

date ,s June 29. Assuming the borrower does not have previous
delinquenc,es, the qualifying payment applies to July.
20502 The PSLFservicer \hd!I use data contained lo the borrower account and ProwJe procedure
--
serv1e1nghistory flies to determine whether qualifying payment~ were
made while the borrower's loans were with the original servicer, for the
period of qualifying employmenl.
--
PAGE 8 OF ED·FSA·09-D·0014i022
Altadment 8 - PSlf Sln<j'4t

SO<V>O&r
fi&Qu.....,,on!3
EO-FSA-'19-0-0014, Tasl<Orde< 0005
P~r>n,Y,vanoa Htgll~r Eclua,Uon As••m11-.;9 Ag,,,lcJ, 1PHEAAI
I 205 OJ , A monthly qudljfylng payment or calendar morith of qualifying

I employmem can only he match"d and counted once towards the 120
months required to apply for PSLF.
1
' Example· Borrower submits ECF from Employer)( for dates

January-December 2012. The following year the certification from
Employer)( includes dates January 2012-0ecember 2013. Since 12
months were already matched with qualifying paymenls for 2012,
the new certification would only match the 12 months for 2013.
205 04 The same period of service may not be used to quahfy for PSLFand
T,-acher Loan Forgivene-ss, Se-rvlceIr. Areas of Nation al Need, and the Civil
legal Attorney Assistance and Student Loan Repayment P,.o,irams.
200 00 The PSLF §ervker shall include PSLFIn exl$tlng procedures for Commitmen1
communlc.iting with borrowers throughout the fonn collection and Statemoo1.
review process when applying for a non--dbcretlonarv benefit, In
compliance with existing Oepartmental guidelines (see CR 111258•
Compliance with Higgins Decision). FSAwlll provide additional guldarn:e
on language specific to the PSLFProgram, as neces,ary.
206 01 The PSLFservicer shall maintain records of all communications with Elecbonlc catalog of
borrowers throughout the form collect Ion and validation process. FSAwill forms, letters. and
corrnspondences
provide additional guidance on language >pecific to the PSlf Program, as
the PSLF s0f\llcer
necessary. uses to
communicate with
the borrower
Separate writte-n communications should be provided 10 borrowers: regard<ngqualifymg
paymenls. qualifying
employment, and
I Confirming that the Certification form was received,
PSLF elig1b1l11y
sta1us.llracking.
Informing borrowers of the process of validating qualifying
" employment, indudlng the roles and responsibilities of JII entities
,nvolved in the process,
•ii. Describing the actions the borrower may take 1f any required
information I., missing or if the employme,it cannot be
determined to be qualifying, or to dispute a determination, and
The outcome of the initial review.

"
206 02 Upon conduding the initial rev,ew of the Employment Certification fonn, S"'8 206 01.
the PSLFserv,cer shall notify the borrower in writing or electronically of
the number of qualifying payments made whole employed In qu.ilifylng
public service, based on the dates mdicated on the current and prev!ously
subm,tted certifications, and the remaining number required towards
becoming eligible for PSLF.(Note that a borrower must apply for PSlf
using ~n application form ttiat shall be provided by the Dep~rtme-nl, and
I
I
that a borrower Is also required to be employed In 1Jualifyiris public 1ervice
when applying for and receiving forgiveness).
PAGE 9 OF ED-FSA--09-0--0014/022
Allachmon! !j - PStF Sic._io Sor,!CO>f Re<1uare<•H>1lt,J

fO-FSA-09-0-0014 Tasl<Ure"' rJ005
Ponnsr,.,-,a H,gh"' Educa!oo A<.$.si.,,x~Ag,mc\- :PHEMI
' The PSlf ser111cershall ,ndude In the notification a llJtement

which reminds the borrower that to receive ~ny forg,venen
I
Linder the PSLFProgram mmt of the loan paynwnt~ mus! be
made under IBRor ICRto have any remaining loan balJnce after
120 payments have been made.
207 00 The PSLF,en.oker shall !rack the number of matched months to Commitm.,.-,1
determine when a borrower has reached 120 and Is eligible to apply for slalement.
PSLF.
L___
207 01
___
~- - ----- Semen shot
The PSLFservicer shall display a borrower's PSLFtracking dat,i at the loan
level on !he borrower view.
200.00 The PSLFservicer sh<1Hreplace 1he data elemeflts contained lfl the Screen shot of
existln, PSLFRepoft requlremeflts with new data elements as Instructed, sample report.
and provide the Report to FSAon the requestl!'d schedule. see Appendix
C- Sample PSLFReport
209.00 The PSlf servlc!!r shall rl!pOrt tracking Information (matched monlhs) lo 1STwith NSLDS
NSLOSon a new recant type p!!r ln<;tructtons published ln the oau, (appropnate
,nlerfat"e
Provider Instructions, as required for performing GE calculatlon,
documentation)
PA.GE to OF EO-FSA•0!}.0-0014/022
Key Tenns,
"Qualifying paymenh~ refer to those payments th~t mret all mter+a specified ,n ~equirPnwnt
Ul, independent of the borrower's employment status.
• "Matched months" refer to tho;e months ror wh,ch quahfy1ng s'mployment h;,s been validJted
and matched with months of qu;,llfying payment. These months are eligible to count towards
the 120 required to apply for PSLF.
• "Valid Employment Certiflotlon form (ECFr is a complete, signed and dated form, which,,
certified by an authorized official from a validated qualifying public serv,ce orgamzation.
PSI.FSingle Servicer Proce,,, Oedgn:

• A borrower i; declared "on•track" for PSLFby submming a valid Empl9ymen1 Certification form
(ECF).Once an ECf 1svalidated, the PSlF servicer will request (pult) the borrower's loans from
the original servicerfs), where they witl remain until the outstanding balance of the loan(s) are
discharged, pa,d m full, or defaulted on.
• The PSLFservicer would handle the tracking of qualifying payments, collection and review of aH
ECFsand related communications, matching of qualifying payments with periods of qualifying
public ser.lce employment, and processing of forgiveness when the borrower 1seligible and
~ppl1es for this bens'lit.
For a borrower submitting an ECFto the PSlF servicer for the first time, If the form Is
determined to be incomplete or does not support PStF qualifying employment, the PSLF
servicer would communicate with the borrower but would not pull the loans from the existing
servicer until the borrower submits a valid ECF.
• All qualifying payments made prior to transfer to the PSlF servicer must be looked up using the
borrower history and servicing records, In order to match with periods of employment.
PAGE 11 OF ED· FSA.(J9•0·CJO141022
MWme ....6 - PSLF SingM s"""""' Fl"'l~I,-(.

l:O.f'SA.;.-s-0-0014_ rasi,: omo,ooos
Pormytvor,a H;gr,.,r fduc"110n Ass,.1"'1al Agef'C)'JPHEMJ
APPENDIX A
rSLF Employment Certification Package
PAGE 12 OF ED- FSA-09-0-00 141022
PutJhc Se,v,ce Loan FOf\l;vooess Program
Plank yllu for ynur ,nteres1 "1 the Public S,a,vocel°"n Fo<go.ena.9 lPSLF) Program lor W,ll1am D. Ford Federal Dlrocl Loan P,ogram
ID•rect Loar,) __,"""""' Enclo,ed you w,i nndthe En,plO'fm&nt Gernflcatlon ro, Put>llc s..,,.rc<>Loan Fmiwenesg (Employment
Cer11flcal""' form) ar>dtha accompanying lnstrucliM• for Compl61,ng me Employment Ca,!>(tt;atlon form
The purl)ose ol lM PSLF Pfog,am ,s 'O ,mcourage lnd,.,;<Jualato enter am! oonl•nue ,., !ull-!ime pubhc sarvk::e employmanl by lorgn/ing
lhe remalnlr,g ba<~nce ot lhelr 01rec1 Le>an• alter ll1ey have made 120 qua1,1y,ngmonthly payment• on th<Jseloans wh~e employed jr,
el'(/,b,hty r<><1u~emenlsol11le PSLF P1oq,am. t.ow you can verify lltal yrur empfoyerqualines as
publ,c ser..ce. This lelter explain:, 111@
a pubic service organization, how to !rack )'OUrqua,ity,ng PSLF p,,ymeots. and lhe pn,<"-""S tor "PP~"'U for !orghleness of your Ora<:t
Loan(s J afl&r )'OU hi1V&mel Iha &l19IDd1ty<"{lulr&m!H1to.
Ched11st of Ellglbllit1 Requi.-..rttants fa, Public Se,,,lce Lo•1> Fo,wlve118S•

The loll°""ng ch&c<hsl .....I he4p you d8termne ,t you may b& eUg,ble lur PSLF. You at<t eHglb~ kif PSLF ~:
n You are not In default°" the loan(,) to, v,t,lch yru ""' requ,,stlog Jor~ness.
□ Yoo have made 120 s"l)araie. qualifying moolhly pnym,,,,tt,• aft..,. Oc•OO<K 1, W01 on the Olr&el Loan(s) ro, which you are
requesting forgivone•• under°"" or mo,,. ol 1/le followmg ,e~m,rnt plans:
The locome-8as«I Repayment (18R) Ploo:
The Income Gonungem R"P"ymem IICfi) P~n:
The 10-Yea, Standa,<! Repayment Plan•• !Standarn Rep8)'Tl'IM1 PIM withe maximum 10-ye<tr f<tpaymenl peood);
M
Any oth8f D~net Looo ll!Pay,.,..nt plan. "1 which yow monthly payments "'luaf o, e•ce&d 1M rnonth,y F"'Y"'""1
amount !hat woo.ddb,e f"'IU"&d under lhe 10-Year Slanda!d Repaym<tnl Ptan.
NO TE· These 120 paymenis do not need 10 be e(m,.,culrve.
□ You made each of Ule 120 monlhly paymanls on lime (no rater than 15 days of tho schodul&d duo date) and /or al least the full
scheduled on$tallmoot amount
o You were employed full-moo by a pu~c seNlceo,ganlzallon(&) o, ,.,,..,Ing I<>a full-ume AmerlCorµs or Peace Go,ps posolloo
at ttle !1"'8 you made"""" ol lhe "'IJ'-'•ed 120 qualifykig monthly f"'Yntents. Please see Seciloo 5 or 100 Employ"""1t
Ce,tOlcal•on fofm for the defonlllons of "fuff•llma" and "puDllc S<N\llcao,ganllallon"
□ You""' employed full-llm& by a pubtie "'"'""'011J""iz.atoon(s/ o, sarv,ng ,n a Jull-ume Amer!Gocps or Peace Corps poonioo at
the time you apply for kl"'1 lorgj;,,rneoo and at the~""' forg,lveneM'" grnntad.
'I! you_,. M Amer.Corps or Peace Co<p!I Yohm--. you may ,.,wive cr&dlt for making up 10 12 qual,ty,<>9payments iyou
make a -ump •um payment u,ing ~II o, part of a Seq.ti Educatloo Awa,d o, a Peace C<JfJ)strand,on payment. See Sectooo 4 of Iha
enc,osed PSLF Employment c..,,,&8llon fem, (or '1Ala,~
.. IMPORT,lNT: TM St8nda!d Re,pa;,mont P1an lot Direct Con5ololatlon loan• "'11er&d on or after July 1. 2006 have v~
<ep")'monl 180115based on the lo,m amoun!, For purpooos ol quafolylng fo, PSLF. monlhly payments you make under the
Standard Repayment Plan on a 01'9<:I C-Onsotolatlon Loan am only qooMying paymonls ( mQda under Iha 10-yea, ll!P1Jj'!T>elllterm
You mlJllt ;,enfy allot yo,..-qualifying public S&flllceemployrnen1 u•i<>9l"8 E~ Certlr.catlon form(s). v,Nch you may subm,t
wholewo,king towards futnlling the e1igib1lltyrequ~amenls tor PSLF. Or,ce yo<J have fulfilled all al~lily ,equiremenls, you may 8npl\l
for forg"'8Mss by sut,,mlltng a Publ,c 5el\llce loan Forgt..ene"" 11.pp~cauon. !AOM lnformatloo or, Iha,,. fo,ms ;•be'""'·
Employment Cerlffleatlon fo, Pt>bllc Service Lo.an Fo,gh,en.a•
or yoor qualifying P"°""•c ,a,.,loo amp1oyment using IM Employment
To qua411yfo, PSLF, you a•~ ,equirad lo sobm~ vm1foco1i<m
Cartlf,catlor, forms. RMd the accompanying lnsl<ucbono 10<Compfollr,g lha Employmenl C&r<lllcatlOr>lomt. whoch1nc1000si'1s!rucbons
lo, you ~"'1 yoo, ompfoye,.
You w,II need lo subm~ complate<l Employment C0!11f'k:aton form\s) lo document that you war8 employed Jull-t,ma by~ nublic service
o,ganizallOn(s) when you mad~ each or :he 120 quallfylng monthly f"'tmar>1s An akJlhort:zedcmc,al or ":>Chpublic sel\lk:a organlzauon
ihal you wo,ked lo, whole mak,ng Ille r,;,qu~ed paym(mt,, mu•I complete, sign and dale Vo'-"Employment Gartrfocatlot>lom>IS).
II you intend lo epply ro, PSLF, we S"9'J!IS! Iha! you cotlect emplo~I certlfk::atlon(•l from yourqu,.ff);ng empJoyt>t{s) wMe you are
makmg lhe r"{lu~ed 120 qua,lf\,lng mool~ly PJVmen1oon your l<,a,,9, You may ,ubm~ Ifie Employmoo, G"'1iflc:atlon fon-,,(s) annually,
wtieMver you d>anga employers. nrwhen you app~ kif PSI.F aner you h""e met !he el,glb<lity r&qu~omcnts for loan fo,y"onoo•.
11you choose IO oubm~ Employn,ent Cefl,f~lion fonn(•) oor..-e completing the 120 paym=ts and nppfy•ng for PSLF. you must sand
lllem lo your Dlre<:t loan ,;ef\l!Cet. MIO man.:,g"' Ille napaymoolof ~ ~.-..ct Loan(s) or, 000011of the US Dep...-lment ol Educaloon
(ll'H, Dapa,tmenf) The Dapartm,rnt wol con<Juctan ,nl:lal , .. .,;-10 check tile Emµloym,,~I Certtffcallon l<>rm(s) are complete, you,
emptOI"'' qua;,tle, as e put>tlc ...,,,Ice o,ganlZlltJon, er,<(!he l<>&npeymMI• you m1!de 1uriflg ll>e penod covered r,,,the Employment
Cer1rf,c;,110nf!OfmSa"' qualjfy«,g p.,ymer,1"
8,onaflts ol ,ubmiltln9 0,., Employm,ontC•rtlflcatfon fonn(s) belo.-.. Y"" OPf!ly lor PSL.F:
PAGE 13 OF ED-FSA-09-0-0014/022
Mw-'1menl B - PSlF 5io~le S"""'-"' llogu·r-,

E0-~5.A.()9-0-0014. las.t °"'"'['1)()5
PoMsyM,n,,. H•(/1'"' Edv<ab<ln /\,SPSl&n<"t,g.,ney (PHEMI
Th<1Ot,partrrnml w,I1,.,ta,n too oriql<1al C<>rlrf.Qltron(>Ilor you unt,I ;oo a~ply to. PSlF,
n,., Oepart..-1 willackn<>""""1ga reca,pl or your Employmanl Ce,tlliC-"lio1Jt
rompl<>t•ly.and
wh<>lharY""' c,,My,ng employer 19 a qual,fying puOI'<:sarvle<>organization
D<>l<I,...,,...,
n,., 0..par.,...,Pt .. ~1match '(OIJ' ~.-ify.,g Joan pd)'rnents 10 the months Y""' were employed by a q,.ar,fy,"11 p"bl'c """'""'
organ,taltoo, baS&d on lh" d&lM provod<'don 'I""' Employmerrt c..rt,li<;ation form. Y<><,"'"' b<InoufiOO rnwnUng of the num"""
of quaiifyir>g payment, you MY" made and Ille romamlng number ol quaUfy)r1flpa,,mer,t; ·,ou muol make !Holore '{QUora e.rg.ble
:o apply lo, PSLF
Wh<>n you ,tmd ,n ,.oo, appl,cation ror loon forgMI005s. you ~o no! haV<tIO ro·wblntt EmplQYfllelll Cartlf,;;a(too (orms JD<
p,,r,oc!s or "mploymanl !~at hava alr,>a<fy"""n validated by lhe Depanm.,nt.
Colle<:1ic.gdnd ,ubmoltl119 the Employrr><1ntContfica~oo fo,m(s) wt,lla )'<)u aro ma~lng the <&quired 120 quahfy,ng monthly
poyrn,ml• wrll help you ke<1ptrack or when you w,11b"ellglble to aPflly loo f'SI.F
Note the l<1Mowl119,

11lhe °"VMffl8nt delomUne,, lMt tho form(s / you suom,nod fS 1r,comp.a18, I/lat your employer dC>Bsm;t quahfy as a publ'c
so,vi<:<Joryeniwtooo, or :ha! you< loan pa,ymen!s made ~ring lhe panod coserecl by !he Employment Cerllricallon(s) aro nol
quehlyl<,g pa)'rnenla. lha Depallmenl WIii,>01,fyyoo m wntmg. along wrlh lhe reason(s) br Ille detam,.-iallonls) and U..., sleps
you musl :ah to complato 0< correct lhe pr<Wloo•ly su~rnll!Old fo<m<s).
II you sub-rni lhe Employment CerOflcalion form balo,., you we olig,ble for PSlF, lho Oepart..-1 wm '"'" ~ In valioal<>l!ia1 your
employe< ,s a qua<dy,ng publ.; seMce organC?"atlon.•• defin&3rtmM1 canr,o1 ~eterm,118
,t you ara etig,b(e for ioan !org,seneM unlil ,ou hase out>m,nod e PuMc SelVlc" Lo"" ForglvMon Appllcallon to you1 Dore<!
Loan servicer,
You may qualify f<>< !org"'6nos$ of Ille ,ema.-ilng b.alanc,i ol your Olrt,ci Loan(s) only afler you have made el 1;:o qual,ty,119
monthly paym&n!s white p,ovlcllng quao;tytng public ... rvlce. a, <las<:nbedatiov... You 00 ,,et rec""'e panIar forglv<1oe•• b.asod
on maklr>!Ja los..,.. number of qualolylng rnonlhly paymoots.
To qualrly tor loan r0<glven,,ss you mus1 beworlo:lr,g ro, a qual,fying public ..,rvlce orgamutlon at the 1,me )'OUapply !er loan
ood al lhe lime torglvenan Is granted by lh<IDepartment.
f<><glV<>llft,IS
You should k""P COi>""' of any Employment C8rllnca11an ro,m(•J you submh lo "/QUt"O•r9CI loan seMcerfor y,,ur records.
Public Service loan forglvanua Appllcallon

Only q,.oalfylng pay"""'1$ mada altar Octob0r 1. 2017. wt.Meemployed In public seMCfl. may be counted !Owan:I lhe raqu~!!d 120
moothlypaymools You may only subm~ tM Public Service loan F"'glvanes$ Appijca1ioo afteryw have made all 120 quahfy!ng
payments and m<>taI1of Iha 01her allglt.llity r&Qu~ements. "" descl1bed anove. Thereton,. 1h<>earl"'"t Ml" !hat any bormwarwiN be
a1,g,bl9 10 apply ror and roce,ve loan !o<glv<1nessIs O.:tober 2017. Tho Publoc S.rvlC<I Loan FOfglveno,.. A.ip11Cal10nw•1 ba available to
lhe public befo1e Octcb<lr 2017.
After you submi1 Iha Public s .. rvlc• Loan Forgl"eno56 ,<r,wlleabon. the Oepanmanl wrll revlow your App(leallon ood any Employment
to be el,grb(e fo,
Cef1!!1catloos not prPMOUSly,Rlldated by 111ftOepel1mer1t. and de!e<mine ,f you have fulr•lled all of ti'>&,oqui,am"""'
PSLF.
Supp,ortfn9 Oocument.tlon of Employment

It Is vary Important lhat you keep 1e,;;or<lsof~our qualllyfng public service employm.,.,t-<ndUdOlg W·2 forms. pay stubs. and any olhe,
documents domonstralmg yo,.ir 'll)al.ty,ng emplo1mer1!-lo, addJUonlo cov•e• of any comvk,l<ldto ttlo Oepartmant lo ,ovl8W. In some caseo, th<>De>'811mentmay raqu,re you to p,ov,"9 add•llonal suppo,t,ng docr;m.,n!al,on
of l'°"' quahfyiny eoiploymefll.
I( /OU are unable to obtain an av!h0!1Zed ofllclal"S slgnatu"' on the k><mbee8lJS8 you w9te employed at a publlc "8fVlce organ1Zation
1~at m ror,gor axl,ts. compiete Secuon 3 ol lh<>Employment cenlflcallon fo,m accordlrg to lho guld3nco under /nstroclions IOI'
Borrow1>rswhan !hero ,a f\/o Authorized Offi«tJI. Wh"" requ.,,!e-d, you must be able lo p,Olada 11,.,D,,p..rtment w,lh sufll<lent .,.,.id...-.;e
t~al supPOrtS your qual,fy(ng &mplo\ln19nt and tho stalus ol y(M.JfqUallf)"ng public s..-vlc:8 organizallon al the t,me or your employment.
PIMse do not •ubmil any documentation other I Mn complelOO Emproymenl C"'1Iflcat00 forms unless roquesled lo do so by lhe
Oepanmenl. /J 1·ou ra,t lo provide the Oei,>artment w~h acklitlOnal esldenca of you, QUQhfyir,g)'.N.Jb!1eservic,;, ""'ployment upon ,eq,...,1.
the Department w,11!M unable 10 complete ~s ,.,,,_ and )'<)Uramploymenl ir>dlcaled on Iha fo,m cannot "8 doomed qualifying,
Time Required for Review of Ernploym•nt CartfflcaUon Form•
Geoemily. ~ will taka 30-60 days for \h9 O.,pan,...,n( to complete i1s ,evlow of any Employment C..n!flcalloo form~ you submil a.-.:Jlo
001onnine v,hothor your &ll'{lloyer "' an et,g,ble pub41c"""'""' organlzal•on. Prooo,song may ta~a ""1ger ,1your Employment
°'
Cen,f,cauon lo<m• am ,nwmplato or If \fO'-' your ernploy&r dou not rnply promplly t<1requasts for more ,nl,:,rmallo11
Add~lonal lnlonn.otlon and As•lstanca

For additional ,n(orma\,oo on 1~e Put,4,c Servica Loan Fe<g"'""""
Program, indud,ng a Fa>l She<1tand 9.80.~see \h,i \J.5
~:era□ ment ol fg",:;u!90'i Puto1IcS<,fVIC<JlOJO Forglvene~s Wfb sot\l0<contact your O~ect lo,on seMce,
PAGE 14 OF ED·FSA·09·0·00 14/022
,\[1"""'1""! 6 - P~l~ ~<ngla 5't<vlcer la9Qulf..,-4ml, Pago t1 or;,,,;

EO F~\--09'-0--0014. Tasl< Orne,0005
f>ooM)0/11t11aHMJl>erEdocatJOO.,,.,,,,1~r,c~ ,<gartG)I{PHEAAI
,_
E<ro,10~
,...,.,
hmodlUng,..ld
..
•• ,,....od Instructions for Completing Employment Certification for
Publlc Service Loan Forgiveness (PSLF)
Wllll~rn 0. Ford Federnl Direct Loan Pronram
li.m :Zt-,~"•"' on, olt,o, o;,.,,..
Ca'80#y
..,_,
"'°"""'
• "°"""°'
..-io- Ooo<
r<<p,amonra al "'" """"' -
L- ro, ~.!o,m,..,,, st><,,,!U,o
Loon ,.,,,,,_..., (PSLF)
wt,,,;fl .,,.,...,,..,.
...., ,c E,,.,,_ """"'"""•

.,.,,.,. (ru,n-.
,och
!o, .,_,_,,,.,....,
•• • '"'""'
D"4d Loan(,!
o, """""
•-on!
muno. """"'
,...,,c
'""''""
P<o0-.. •ho mom .. by ""'l<h J'lU moy .,,,.. .,.,..,, """""'"" ..........
.,,,
"·""'°"'",_ """bo,
,_,
•...,.,,.,.,.n
•.- .......,,_.
"""P<'>'~"" ..... ""'"""" .. """"'· # '"'" ................ "°'"'...,,
-
....,,__
" • ,,.,., .......
....
to, "' ~
,.,_ ...... ~-
must'"' borh >""" """"""""' """'"'" o-.d '"°'""~

o40,.,.
ln<h<don, ,., !loo B"""ww: ......, -•tho .... <--,.,..,._,,,..,,,,.,."")<"¥"""'"
"'°.,"'""'Em-•OI
""'·limo
,.eno'J,-,,,.,, P""""
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,_
("""°'
I·< •"VI n, •-
""'fl'oymonl """" makk><j..,
to
,._,.,.,.d
lelO...,.,_ -
___ ""I othoo-loiepho•• at
!°"""'"''.,,..f<!.,
-·-· --
yo,, "'" ..... M ••-- wh,,;h
'"""""'"'~:.,.,.,mno<••""·
120 '"""'"'-· q,alfy~ """'""' ~""" ,......, 170 o,,.,,,...ra 'l"•'"- II- S (-no!~ po- o--ma!t ortdr<>" b ,.,;,>1,"'11
,10 ,-.-,,h•v. to 00 """""""•""'- Fot po,-l<Hh In ""'l<h )"'U u-r• E,, •., ,_
"'°'°""9 °""""""""'''""
•.,_........,
...,,.,,.,.r,d
<or,cUff8ruly
....,....
or"'•~""• ,........
,-.,.,..,
<>1'1-
....,p1.,,,..,,.,""""""
,o --· - ....
dh .....,.. "'"" ..., publl< ,.....,,
,ut,,,,11 Emp1o...-,1 C"'11ftcotkH,

")'O<Jfl'-.la
'""
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"· ............ '"'"'- _,.,
,_,, (p-, M) ro, oa<O. -·

SECTION l, BORflllWl!lrS CEA.TlflCATlOO/REOUEst!I.
V,:,; "'"~ ""'"'" ao •'""""""' om_, ew<>,.,_t.c,,"" lt,o Emplo_,,. AIJTIIORIZA""""5. ANO UNDER"UNOWOS
c,a.<ie..io,, r"""' ~o,cn ''"'"""' ... ..., • ., """ o;,..c, '°""_..,., ro.o
V.S Ooo•"'""'"'ol Ed""8000
•boot-mo,.,•o• "'• ,_.,..onlonO.o<O l.otN,
"°"""cl•"""
••- S-luloflaf
Lo""''""'s"".-io c.,....,
~ ond •'9"an4dal0
,.o,;11"', ,oqu.,i., ao!ho,-.,,ltfon~ an,j """"'loodk><jo In ""'
"'°'°"" ""'""'='•'"
Eo1p1a...-
PSlf l•Ofl-•I
C--
.,.,, __
"""'" bolero Y°"
-
a,o to.,,,,,,
ollg,blo
ta •-«•tlllull<>"•
k,, •••••
C"'1&ation
PSI.F am-nt
!oon, ""''" "'''"'""'"'
eok.o ,-,,.....,.
C"'1"1caion ,.-..,_, ..d..01"'1
'"°"'"O,o<
Ill•
Emo'o)"Oont
0om,,,o,
"'°
lo<lo•
••nually"' ,....,,.,., ,ou ,.. ,,. , _.,.,.,, p..- ""'"10llog your
001P'<Jl"'""'- ,00 .,. ,1111 ....,,.,yo4,,
o "'"'OljvM] oo,t;,c .. ,,,,"' SECTION i, camtaeATIOII OF E"'PLOl'MENT
O<Oll'"""'°"°'"'""'"'""'"""'""""'"""'"'"""')OUr"'ll""''"'""'- E,.,,, your nomo ""° o,i,o.Jlglt Socio! $arun" Numb"' ., .,_ ol J>&!l•2, kop
OI .. ou,.rw1... '"""'"'" "'pn>·M• • ,,.._,,
... """" •Pl)I) lot PSlf "
,ho,._not 10 ,..,._, Empl0,.....01 C"'11fl<o"""'''"'" ·- mo>l<ag<no ~""',,,.,,,....,;,
)'>''
oJlel.ll °"""
,ou
"'""'°" 120 ~u,I•",<~ "'"'"'"' P•~•-• ,ou "'i "- ""'m An outhon,.., h, '"""'"
!ho""""°....-,.,. "'9""''"""" ot """"1 you
"""" ,- •P<'Y PSLf (o, .. -.,. aru;t .,.,.,., .. Soc'"'" l ff ooy ""1.,.>loO ;nlorn,oOoo
~
• "-"o__,,. ,_
•""'"""(•))"'.,,tm,"°"I"°"kd>m.l.,. f>SlF
°".."""'"'
onEmpr,:,,,,,on1
"""""°"""·
Tho
c""""'""°"""'"1""",oo
b•""•l""J ,,. ol>;lolom appl, IO<l0<ylvo0ho, .,_ D,pert,no,,1,_.,
,o<aln
...nrnmo..,, an ,o.,,. '"""'" to '"""" O>OI,,,. Ert,-nl

io_o,ml00in9
""""<~""•
ff•m 1, "'"'""'
1M ~~-od {Qf
C"'1...,.!N)n ...,,, fo,<lo,.,_, ol
Offl<lal (,_ s.d'°"
iho ,_.,od,ofO<Tt>&Uon otx,u,"'"

~<JI-
1ho~-ntcanool,a"1at.lllac,.,.il<•-
O<'Jtclal/
5 ol lho o,,,_,_.
,..hll<; """"'
CoMTcalon !om>(•) .,,, <Dmp<At.,"'•• I""' omf",,.,., ~•..aOf,o,
"""""°"''""''""'· ahd
•• a pub'le
po,..... .. ,oo """'' ~ ioo
""l'>"'UI,.,,. at""''".,_
botto...., fSlwa, ""'"""'"· •"'--l "'•
"'"""°"
P""°" "''""'"' b) 1no Empto""""'
lhar lho .,_,.
Cori,J;ca<k,,-•I .,. ~ "'°"""""-
,,.gon,,...,n·, nomo. oo,mo..,.
>lumt>o•iEII,(
o,ll,o,.,
-wol•bo
ahd """'""' Empto,.,
UO<dlo,oofy ,olomu,rJon •-•
""""""
W)'OU ouomll .,_ Em_
,oo •-•
.. Co""1<al•""'""">!•) Lo lho
... •oofc;>tlon lot PSLF ,<,u ...,,, ,O~ '""""'
D-••
'" EmpO)IDO"'
bol-
,,,...
....
O,gan/t.Oll(>n
,., Pfc, .... .,. """"""°"'

,..... g "'" _,,"9 - ..... ,,.,,.._.,._
owbllc
'""""o,pn,,.,.,.,.,
""'"''"""""°",t •ho !M ...,,.,_, " ... ""1plo)'"""" "'ff>l!!ZO- .. tho""" 1h•
C.,rtlOa,.,,,."""' lot "'"
,..,. ,oo """' ,.._ OllOata ~r,•lod loM ~,.... '""""°""""
,,~·""'· ""'"f•.......,...""'""ti....
pur
IN9TIU)CTIONS fOR COMPl.ETiflO ""° SVBMJTTil'IO TffE M.,,, :it,; "'" "°""""''
Che<k ... 00> tl1'>1<111""1bo, omo.,,m..,t ''""'
oml)q'OOn•""'"
full-lfmo O<<O«loncs...to.,..,
00 .,rvt<>n Soct>ooS d .. ,a
EMPlOYMEOH CERflflC• TlON FOR PUauc SERVICE lO.ON
e<ll,o Emolo)"Oonl ~-- "'""· p,.,,,.. lho ... ,_ oomt,,.- ol t>ou,-,
FORGIVENEH
, '""we""
tno """'- ...,._,,,,t<Op!o)'I!'<,o,lhOt Ml-'"""
"'P•~-'""'·ol rour
'""'"'"""' ""ntlblUo~bl"" lnl<, '"""""
llom
"""1"'""'·""""""
,-c- ....,..""".,"ljon'7,!00
...,;.a••gc,)'"'"'"' ...,....,,.... ,..,.,,"""'"
S- ,t.,.. •• rnm-M->'IYV
,.,. "'""'or.. show 'Jaou.,., •s. ;,u10- ,. .. ,,v!ca "'l!"'"D"'1 •Oa ,.,.... .. O<g.,n,_
" )'><" '""'
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"""'""""""""""""''w-,.,100.-,.....,.,_,
••n. ,... ....,., ~•""-•l"'P"""'"""''""°')'"""'-A""'"•-"'-'allon
on,,,.,;.,.,, !ho c.haogo: ony cha"'-'"'In Soctlon J "'"' !:M> '"'""'°., """'oOI q..,.fy •• • ou""c """""' "'~•"'•••'"" ~" "°"'
Ill!!11>,o,j ~
"'"-·
"°',,,....
..."""o<
"' u <,. a 1,,,.,.,.,,,. .,g,n,roo tor r,mm.a iaoo,
,our "'"P"'Y"'- • 'ho'''"'"""" ".,o• '"''"'""- rh•°"r""""'"'m•e"'''""
'"'''""""''au uoklo, • r,i,,u,,.. _,.,.,.,., o, .,. "'II""''"'""
po1a,.,,, engag"" I•
•~ ""<et,>0"110 , .. ga.,.,.
K..,, , copy n• ,ach '"""'"'"" E.,.,,,.,yn,.., C-callor• '""" ("' ><'"'
"'""'"'°"·
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o< ""' lmn o, ,.,,,..i,..,Jno
Co_,,....,, Carow, 0,04 .,. ce,t,/lce"°n ~•-- ""'' ,,-,.,, .,., •~mo
""' !ho oog,nal oomplerod Ernploym..,, C•"""""°" foon fr•g"' I •2
ooly\10,..,,Di'OC!looo"""'°"" and """"'" Ho ,• .,. •.-- -d ,nd - • ,oioo- r,.,mbo,
.i,.,.,,. """'° ~ can bo '""""°" •"""'"°""'""'""''"""

"'"°"""""'"'""' "
You OIi<>"'"'" <<>plH ol ,<1,11•ono1 ......, • .,.,. IN• a,"'1rm
"""""" '''"""""""'"'"'"",p..,,,"""""""s.............. .......,.
,.,.,, -1,.....,.t,g _,.,,,.,,.,..
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'""""" •"J•"'"""n(•I• to.too
,,.o...- ...run1.,.,
1h<> =
Potum .,. Emok>1montC•""""'"'
oo,np1o1e,1 '<>mlhi lho "°""""'
W-110,m,
p""'""" '""""'''°'"r<,,•••e-o- ,...., ,_,. i."" •u-odOffl<l•J; •
olho,oo,:1,tro10•• ■<•1 ""°""° ,..
Aoy
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Ill''"",.,.........,"""'""'"""•
"'""'°""
..-~-•I"'"',.,., """•••""°''" ot'Ot,11•1
•• • JMA>IC
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!,,,..'"''- ....,,""".,."'""""'"
an o,;t,o,,,-a """-""·
""'"'"
..-lo.,.,..,
,.,.1,o, "'" hoad,"',I. </,oo,
"'""'•or,ionl,.-(,: s-.,.,o 1.:1.•'Id J, Yw,.,,,t>o""""'"' o, -••••'•
"'4 "'""'""'
"°""""""'-•onot1o<>Jm""'•""""'•h ..•-•••-,....,.,•.,_.
SECTIClt< 1. BORROWER lllliNTIFK:•TION '"""'"--·••-
"""'""
...,_ ...-·- "'°"',.,.,
......no, p,....,'9<(-
ft•m
T fn.,..,,,.,,......_.,,,,,soe<o0""""""""""'"'·
, .....,J.,f•r.,,.,.,,
......... ._,_.fi,,.namo..,o,,_,.""""' '"'""°""""'""'°ll'""!omt,.,..,....,,o...,,t.,,,n
"""""''
Emo<o_,•
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c...- t,,,m. "°",_ '°"'... "<'
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on... """""°' Sr<<!•"'
PAGE 15 OF ED-FSA 09-0-00141022
A.llachmoMI 0 - PSLF SO,\l"'I S,,.....-.:;e, R8Qu_._

fD-FSA--0',.0-0014_ Ta.. OrdOf 0005
F'"""")'i'v'>nla H'!jri., EdlJC811oJIMo.,lancR ,0.,or>ey{PHF.AAI
, .. n 0••.a s,,....,,,~5LDSI >IJl~.~.!11'.1. ,_,_,
""'"""'""' con !>o""""' on "'" ~,'!f_Ol:=.lJ>..:itil.ft."1'.~~
-• DEPAATMENT USE ONl. Y -• 0..8"" ,...,_,...,
ORIGINAL'IECEIPT DATE· ""'°"""
e.,,e~.,,.,
Fom,
•.,"""'
Error!
Objects Employment Certification for Publlc Servtce Loan Forgiveness (PSLF)
cannot be WU~•m D. Fonl F-.1 DI«« Loon PrOll""ffl
created WARNU'IG: ~"'I poown v,t,o ~n~ ,i,ako< • laloe ""''"""'"' or "'""•P<•-t.!.,.
on t,,,. r.,...,.,o, on aoy """""'"""Y'V docu,-os<, ,.
from editing ,uti,e,-:,
!o..,,.-, ""'°"'a~""'""'"r,._,,,_
""P-1. Ofbolh, """"'"'" u S, c..,,-,,. Coooo<><t
20 USC 1097
neld codes.
WSTRUCTIONS FOR COUPLET/fiG AND SUB.wTTIHG THIS EMPlOYMEHT CERTIFICA110N
Road lhe accompan)'ng w.tru"""""lot C01>pl8tir,g11,,9Emplo)"\'lent C..-,,fi<;al!Mfor Public Sc,,..,ca Lo:Ill FoniMII'••• Type o, pnnt """'9
1,..,.. <>rblact.. inl<_You musl """ and da!a U.• !om, ,n Soctlon :/ an<! an wlh<ri,e<J offl<,al from ti'!<, pct,l,e ...-,,.;;a ocganlZa~on whtdl
o,-nptoys/om~<>d you m.,.. c°"""a1..ry fMIout, sign and dale Section 3 II M)' lolo,ma!im,s c:msSf>do.JIo, allet<>d., Soctlws 1 u, 2. you
"'""' .,.,;1>1h<lsidR the d>a • "'" ch;,eoes in Section 3 mus( h<I ,,.ba!oo
b r ~- e,
SECTION I: BORROWER IDENTIFICATION
...... '"'"""' romo<, ... ,.._ "'"'"""'""'
1, 5SN Ll.___J__J · LLJ

1b F_, Na...
• (f """""""'"' u,, F;,,1
•
c,.., s., ,.,_
'"
,.,..,~., •• _ 0111..-
, .. Z,pCo4o
s E..., ..
[ SECTION Z: SORROWER'S CERTIFICATION REQUESTS. AVTHORflA TIONS, ANO UNDERSTAHDINGS
PAGE 16 OF ED·FSA·09-0-00141022
Alladlm...-.t B - PSlF 51ng18 s,,mc,,, R"'11Jlrt1"""11• P"lj~ 13 ot l6

tclJ-t-SA..:!9-0--0Q 14 r~'II< Ott!&< 0005
p.,._,syl,onla H,qhe, E<1uC8.!KJn
Aooosl'"1e<1
A9"'9: [PHEAAi
Bafo"' slflnlng, carefully ro~ fhtJ ,nflro lomr, lm:lu<ilng tha lnsrrocrlons am/ accompanymg /attw.
I re<1uut ttial Iha US. Oepartmont of Educallon (Iha Department) ac,:,ept th-s Emplovment Cartlflca~on from tM puN,c service
organiza0on at which I am/was e<1"'ploye<flot oul"]>OS09or qualifying ror Iha PW!c S&r\lle<oLoan Forg1van,:tss PrognJm. I/ I submit
this form be/ore I am ellg1ble IO apply fo< lo,g1v<1ness.I roqu..st tt>al ti\$ Oepartmant reta,n this o'1g1n;>1
curtl~calion form ur,\111
~utwn,11118Apprlca"on for Publk; Sar,lce Loan Forgr.a"8:n
I authorlH my ampto'f'l((S) or ot/>er ..,,111,eshavi,,g recotds about the 91tlploynwm Iha!,. part of Iha basis /or my request ro,
forg,vaness lo m .. ,., informa11on from 11,o.., recorns available to Iha Oepartm.,.,t. ;ncludlng my Dirac! Loan servk;,,r I :>lso aulhart:ze
!he US Department of Educatton and ,ts respeclM1 agents and oontrac1ors, lo wntact ma rngardlng lh,s EmplOyment Cart,ficalooo.
a1 lhecurrentor any future number Iha! I provide for my cellular telephor,e or other wireless dav1<::<1 using aulomated 1et..phone
llialmg equipment or il("ljfic,11!or prer8Cord9d vmc.11or tal<t mllS$3geS
I understand lhe1·
(I)! may only qual4y for Pub!lc Se<Vk:e Loan Forglveoos.a after f ha,,., made 1?0 separate. quaMfy,ng mon!hiy ~,dyments en an
al,~ble Dirac! Loan. aner October 1. 2007. whole omployed full-Ume by a publ,c &eNlce organr1allon(s). or serv,ng ,n a full-bm,,
AmenCorps or Peace Corps po,;illofl, ,n acwnlance w,lh too defini1ions ,n Se<:llon 6 Thasa 120 payments do n.o1 have 1o be
C<Jnsacuth<a:
(2) I must be employed full-bm<1 by a publ.: sor,ica organ~aHon{s) or .serving ma fuli.tlme AtnM;(:orps or Pa,ice Corps pos,llon a!
Illa t,me I apply for IOan forgiveness and a1 Ille tome lhe fo19a,eness Is grantOO I may t,., emptoye<:l part-bma concurrenlty by
more than one ellg1ble public sa1'1>CO organlzatio,, and moot lha tulH,me ,equoremenl:
(J) Only Iha remaining balance ofmy loan(s) after I ha,e made Iha 120 separate, qua1,fy1ngmonlhly payments and met oJI o!her
ehg,billly re{Juirements of 1he PSLF Program may be forglv..,,:
{4) I am not requlre<f to submit any Employmenl Certm"-'!Don{s) before applying /or loan forgM1ness. bul 11I do. the Department wltl
rnv,ew each Employment Certlllca~on I submit to ensure lha1 It Is complete, WIiiverify lhat my emplo)'8r qual,~es as a public
servk:a organk:atlon, and !hat lh<l loan pay-n!s J made dwing the partod covered by the Employment Cart,ficaUon(s) are
qualty,ng payments. fojlowlng H"llsreview. lh<1Department w!i notify ma In wrlffng of the numbe, of quali~ng pay,mml• I hav"
made while employed m qualifying public servk:e and Iha r""'1ainlng number I must make befo,a I am ehgrbfe to awty lo• PSLF.
I woUalso be notified In wnffng •f Iha Department deletmioe6 that the form(s) I subrn,ttoct ,s ,ncomplet<l or lhal my employment
does nol meal tha qOJai,fylngc1!1erlaundeo- the regUJa~ooo. includmg 1118reason(s) tor \he de1ermlna1km(s). along 'Mlh Iha steps J
would need to take lo complete this form orconaci this inlomlat,on; and
(51 The Department w,oonly delOOTilna wheH,er I have fulfilled all oflha requirameots lo be ehg,ble for PSLF atler I haoe made all
120 qual,lylng payments and have subm~led my loan forgl~eness a,,plica1100. I umlerstand that !ha law does no1 penml partial
forgiveness ba;;ed on making a lesser number of qyaHying monthly payments while ,..;,tl<lng In qualifying pubhc service.
-Slgnau....,.of B<onower
PAGE' 170F EO-FSA-09-0·001 4/1)22
Ati;,cho,..,~B - PSI.• So>yl<ls~""'"' Ro,qv•-..,,,~

~O.FSA,<J9.O./J014. Ta'I!<Oro•rOO(l~
Poon•y~.,.~ H,gh,><Edvca"°" A'5,MOf'«> Agency ,PHE.AA)
lk,,,_.,, N<,...,
SECT/ON J; CERTIF/CAnON Of EMPLOYMENT
Seo s.<:1lo<ll ,< rflo
S""""•
,.,..,,,.-"~"'"""
,,...,
Ja,ln,<l<>'I,.,.
o,,o<,mpo,,~•o
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n ·rn
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11>1 '""" on,yw,.,,_,,,.""
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o, pOm u,Jng - Mock.,._ AO- """',.. -,,ph>..., ~ oppllcablo. Y""'"II"""""~,,."""''"""""""'°""'·
a,,_ '""' ,-, (=-dd-Y'IYYI
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...... " ... >OCl><:><li>"""-
,,.<tflcaoonat IM """""' "'IM p,.. Tl-., (m~ Cen~'-"'""' 1o,m
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o.... pl ... d lo"" 10 ,,._ -·
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<,< .... O,=t L,_, MM<o,
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.. "'• .,-gonlrolon .,, -

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PAGE 18 OF FO-FSA-09-O-0014/0n
An:,ctunfn1 !l - PSLF SlnQIQSo,...,...,orR<>QY.r&m.,,11

EO-FSA-09-0-0014, Ta... Q,r:le,0005
p.,,.,. l,,an,a Hi Ed<;c.abon Asorslanco A PHEM
Put,-.; 5.....,. 0.gonl.-,., Aillnl=
i. p.,..,,_•s Emplorm,Q( s_.._
(b) -·•~staru,,atyOI.'"_..,,,_
0 full•Tlme AVe'-l<lfl,,....,,.,,c/J'onpo<--
D Par1-llmo
o! Ol<)ot>IM),
Fe, J)Urj'.>OSM lo< PSLF_ full•- o""r.,yrne,,t'I (lo'-'O~1 "' """ 0< ""'"' jot,, tur ,,,.. o•e"'"' o1;
(Al M ..-.nual .., .. _ ol OI""'51 JO""""' per - Qr, IC>" al al "'"" 6 ...,,,11, .. .-w,
i>On<><l
a contracn,al ot ~~""' """'""" o1 JO h<>.111>P"'
ll"Nlk,o,
(!l) U..IOu ""'q"""',m<J <rn~ ~- lw<>0<,..,,.. "'"olOl'ffl',lnenumlN>,oltou,,, 11,oemplc,yercmsdet!llu!-(11-nO
•2) vacalloo or lo•••'""" P'""'°""l>y!ho o,rpkry,,, o, h>Ovotaken lo, • o>ndrt.>n"81,. • Quai<t,,,,g «asoo !or"-'""" '-'Me, In• FaMII~ ""d l,.IM;,,oj
lMVO A<! ol 1993, 29 U S G 261 2(a~1 I and (3) <IOos ool """"' on,plo)fflOnt """"'
NOTE, /; r,,,t~tt,n, Am..,Go,v, o, p,_., Gotpo "°"'"'..., ~

cmol<lo,«J o M-limo ""'plo)">II lo,- elogi!J<lltyPUIJIO""' !o, P5l.l'
l. TY,>eof PubHc ~ Org ... lz.ollon, In a<COO'<Mffl:• will, !he d•ftnlUon In S..:don 5 (clltock ,,...,,
(•I O A --•M OO'G-Hon ;o,dUOf\!I a Fo<!Oral Stal<> .,,,...,, TriDaU,,_11<,n, ogor,cy 0< eo!ly; opubhc <hid or f1lml\, so,vlc1! ~ or
a TObat c.,19ge or unl\,<>rslfyl:
jcf D A p,tvat., non-pr<>/11organlzallon' t!lot prov~• at loaal ooo ol 11,ort.llowlngpt,bll< soMc~ (,;lie<> ail tnat appl),),
D Emorg,,,cy managornoot,
0 MIW81\f .. lVIGO,
0 Pubbc $0!0,Y,
0 L.,. onlorument,
0 Public .,,O<Mt
i-oer.ic-o1.
0 Ei!ff/- •""""'""' 1""""'"'11r-=-"' rei,..lalod ct,11,; coro, tlo•d S1•<1.aro St••• t,,rodOOp,o,..-.d!l<y.......,),
0 f"-""'<;..,r,,i,;,>ro,,no'!vld.,.1$"'"'~,s;,t,"'"••.-.;llh•-~.
D f>l,t,r,c hoall> i"'<k>d>nQ....... .,, "'-""" pr""1lll00e'I ,..,,. .. "" o <Oriit30"'"'""'· >nd .,,_,.,,. prnl.,..l<vlal$ on,µgo<r"' h•""" """'
pra<.tt1<>ts"eo::upatto•• and'''"'"" wworr ocwpatlornl. as "'"" ,....,. aro ""'"'°"
n., ,,., e..,,,,u
ol l•t>or St,,IIStn).
0 Put,1,:; cd"°"""'·
0 P,,011<~••- ...
0 3,;!,QOIlbMy '""""""· or
D Olt>or «:hool-basod """"""'
'A prlyato 0'1jOrn<alkm dooo ool quolfy , tt" {I) • for-.peolitOOS<nos,.12) a labor ,.-,Kil),or 0) a peJ\ken /K]ltical O'W'n,z.adoo, Mdrtloo<tlly, a
,et,g.,.,,o..,..,.,..11on,,-,ly,,.._ ,t mo --• ,.,~ ~ .,. u...-elll...,h>""9[<1uo""'""1""'. -'P """'"""'·o, proool)UZ>nq
, -~ ir---..
""' bo<n,....- .ienlrllo<I., Sectk>n 1 >bov& - ""'l)io)'O<j at a p<blk: "'MDII OfG""'-· •• lr><lk:Mod _,,.,, a< .,,_,, ..,..,.1,g ., an
,v,o,1Cor_., or Peoca Corp• po,;'"°" (m _,,,,mca w,i, '"" d_,., of tt,,.o ,.,.,.,. " S,e,c,w, 51du,i,-,q :,., period odentrliO<J,n "'"" <(ol ol tt,,. socb'.ln
Aulhor,le<l Ufflcorr, TelopMno
SECTION 4: ELIG/8/LJTY REQUIREMENTS I TE/IMS Al'ID CONDIT10NS FOR PIJIJLIC SERVICE LOAN FORGNENESS
12)
'""
"'""""'
c-._,
°'""'"''"'(•I lo, -
.
C>c""'"' """"'""""""'
n., lnoo,-,,e,.£!.....
n,., ,0-vo..-
My""'°'
Rooa...-
~'"''""'""-•"'
O"'" loon'"""',._,
'"' ~..,..,,:;o,p, ..-.J p.,..,.
)'DU
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,s,..,.oro"""'I'""'"
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-- ""'"'""""'
......,.,.,i,.,,,,.,,,,.._an1..,,...._
I""" ho..
°''""'""'"""9__.,.","'"''-
,,_ •~••or..,....,
tM•.,.., .. ,.,,.,.. ""'l "'" 01 ,..,. ..,.,., "' tho

...- 120 _,.,
10-yoor,__,.,..,"""°"'"'
oa.-.--; 0""""11
120,,..,..,....,_
-.I
•.
nw;,,tlvy
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mon...,po,.,..ot,
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,. 2007, ""'""
""' 5"ndord
In"'°"'"'"- oa<h of tho ,..,...,. ,ZO '"""'""· ,.,,,.,.,. """'""I' po-"'""""'•_,""""' on Omo (no._.,, ...., 1S d'")'O ,,r""' ,<l,°""'od Q,,. ,)0,~1 ond
''"""''""""""""""""""'"""''"""""'-
... PORT ANT· T"" Sla-d R..,_,.., .... Prw, b D,n;d Con_, L-.. ""'°'"°
on "' !llto, Ju'I 1, ,00,. ,-. ,_,, .... '"""""""' ,....,. -, oo lho k-,
,...,..,, Fo, '""'""""' "'Q......,..,""S<,n<oo la,n
Pubic ~-- rnoolhly po,.,..,,_ )O" '"""" u.- "'• $OW,dacd~"""""""' Pion on a O•oci
-~~~'""""'"""J:q•°"Y"'ll=""""'-~""''o--,..=I"""'"""
PAGE 19 Of' EO·FSA,09,Q.QO 141022
AO- B - PSLf s..~ .. s...,.i<..-

R""~''"'"""" Pa,;,ie 16 ol 26
EO FSA--0?-O-0014, fa.,._ Ottlor tlCkY-i
P<K1noyt:,a"'1!H,p Educaboo A.,,.,1aoco llgoncy PHEM
~..-iCo.p.,,,H<o c- ""'""o-., you """" '" "'"",<;°"''" Po""' eo,,,. """" .. '· you '""" '"'""" ., ... '"' ,,,.. "'9 """""'"" "'""""" 1
1o,9,,.,,.,. .. b-,-"'""? .. o,"""' "', ,..,.,€due•- A ..... =•""" .~.,, ,.,.d
~,, .. f., .f
"'" "'"'" paymoM oo '" •·"1""•
• ium,, '""' ,.,.n '"' -h "'" .,. -'II
,,,,,..,c,,,,.
O-,,,on,
,.,..,.,,,
""'"'"""'"' """ o<,Po""' Co,"'"""'"""',.....,..,...
""' ccn•- ,,.. '"'"" '"~ """"""' yoo ,..,, mo,r. .,
I" IN ,,.,.,.. .. 1•• '"""" ...,,.,e_,,.,.
"'l'~"""'d """"'Y-"9~•yrn,ooto'"""' <o"'• ... ..,.
Lho
_, ~"' "'"'" ... r,..,. Co•!>ll n,.
,,r·
""""""D'
'!) ""' f"'"""""' """"""" ... , ""'"'"II lumo '""' ,,.,.,,_o .. ,.. '""""""
OM""""'"'"' ,,.,..,...,
<So '"''""'" ',OU _ .. ""'" .,., .. l"'>OOI""' ul
...""""'""',_)ffl
111•~-,.,.,.. ..._ .. ""1 ·-- "'O ""'"' , ..
P,..,. C<><v•
•olunloo" ..,."II on ••'II""•
rum,,.um .. ,.,,.,., """" do so"""'" ~ """'"'" ol U,o End 0,,., oa ,_,,_., Socllon .l b-,-"'" ou"'°"loO """""'·
Ill Yoy ..,,.,,.,. ~ M •mob-,- • P'Jb<Lo

_,,""' ""lon,uOLoJ>C•Io, ..,,_,,,"' • •.;H,n,o o< P"""' l;o,p• """"°n el ""''"'" ""'•rlC"""' I"" "''"'" .. cf>of"'"
''"'~'" llO 1uolfv>nll "'°"'""
,.._,.....,t.,
ot ... o""o l'Qu -ly lo,'°"' "'9"'- ... or<! al lho 1..,.1o5> ''""""'"" !s "V""'""-
NOTI'. y,., "" ""' •ffo,toi. f<>"P<"V.,. "'"'' - "'"""""' lo .,,..,. ....... uM<lf""'PSL.f P,ug""" ..,oo<h.. ··- '""" _ ..... " "'""""""o
,.,..,...,. '-""17omo '"°'""'"g T-0< l.o-1" fn<\1"00....,, s.,,,,~,. "1Ml .. d ""1k>o,°'t!Hd, "'" logol M.,.la<>co AOon-_., SO""""' Loo.-,110!'0\'"'"'" C>,•
Youm,,y..,.,...., '°'PSLF "'"" ane, ""'""'"moo""' °"9'b"lfi""l"""m""" .. oo,J,t,o,,o Sl"""""'Yq""°'l'!"ll!>i-" ,,,_ oflor&lobo< 1, ,ae, _
""""°"'11"''-g ._,,,._. mavno ,,.,,.oo "'""'d u.o ,.,,,,_. 11" """""""'· """ oom:,,,o,. n,oy""' •«>'v,.,, '"""
O•V""'""- ""' ...... _, d•"' ... ••Ve.,,.,_~ o
.. "" "'lq,bl<,t,, •~ lo, ,,., ->Oct- 1017 A ~SL.f •oe- ,.,.,..,,,,,,.....
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SECTION S: DERNITIONS
'°'f'lotJ"" s"""'"L""",,,,..,.....,..,...-
Lo.,..,o.. , ..-..-g"'•
• F_., °"""'s"'"°'""'otdLo.>o,(O-,, s,o,>ot:todln•n•)
'""""' O<Od Uo,--,&11 ~Oo"'>rOl>'(lfflUlaoo 1""'"1 '-""""""'fe<l
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°""""'""""",nOo
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m•y bo co-kl•!od
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PAGE 20 OF F.O•FSA-09-0-0014/022
Attad"W>l<lnttl - PSI F s,~g.. s ..,.,,.,.,,R&Qw-t, PfOQ<l17 uf 26

EO-FSA-<IS.D-OJl4. Ta<k Ord..- [1()()5
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--,Y•OMCM,O,
SECl'JONe: WHERE ro SEND mE COIIIPL£"fED F<JRIII
Sf:CTIONT: 1114PORTANT NOTICES

P<tvac1._..N~""9. ""' ,.,,,cyAdol 19N \SU. <; SSl•i'"""'~ "'°"'"'
O,,_ng - be..-.,-. IOl')II'
Tl>e•"-•
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§451 OI ><q .§41!1 OI .,,q. and §42'-'l el'°" o<ll>o H,g..,, Ed""'"'"
!06faoOl .. o,and:?OUS.C WIOgo1,oq1aoo,..,..,..,,,,,,...,.ooJ-g
Acl ol
''"'"""" ,....-&o<>ols..,.,,ttyN'-"" ... ISSN)...., §§411113'~on,I 4"4ja~41 olor., HU (20 USC 1"16-l(~ oOO1<l\llja~41)•n.J ft)1001(1~1)0I"" D<>O,Cof\o,cUoo
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Vo""""' o<<Pvldo ,t,., ""'""'°"-c1onfoaooo, "'"""lnQ
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you, o'~b'"'v lo """'" o o,-i l°"", "'
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;h, •olQtmo,on "')'D"< ~• m"I' ••<)><-.on•

co,o-t,y.co .. b,.., Of'-"'..,•""""'-''"'
malct,ng program, tt,,d - lo
" ou..,,.,od ~ iw1"" o .. ,., lho
"""""""'"'
For• ,..,,_ ""' """'"" " ...
hlgn..- °"""""""•
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ta Lo"11p'"1)1...._,,
io ,_.,._ slala. o.- ioa>I •O""""''- lo"'"'"'"""'
IOdooormlrlo t<JUOligll"t)I 10 roc:oNoe loan, lOm«ollpato ""''"'"" ITTl!>d,"'"" to,...., romp"'""'• "'"' 1.a...,1 ,1w..,1
cl
f>ranclol..,, program re,paoon._

In lho .--,( ol !O~llon . .,., moy -,d <e<O<fl l<>'t>oOopaOmonl of'""""·, °"""
,,jj,,oi<o<Nobody, °""'1WI, ,,.o-y.
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olsd<><e, .. mav o. ,,..... lo <I""""'" - "' "'"""""""',.,,, •-• ""°'""""'· To ''""'"' ya,, In -)ffl•Ol •ll'ort>. <hci<mucH ""'' o. .,.,.,. ,"11'-"'''""
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l'o- ROOOO<lonN-o "'=<<i"'l tt,, P•-0, R.od,,<- Ad ol 1995, no-• o<o •- ,o -• "'a __,,. o1""""""'""' on'-n t ~play, a
"""°'"">oil<!0"'8 ,;oo<rnl•"""- Po!>I~ '"""""" t,..-, .,._ ... ooOocllao ol lob-mo,,.-.'< "''°""""IO.,,.,..ii" X.X"°""- (H """C-) O<""<0<pon.. , ,nclud;ng
, mo """"""""" ,n,l•K"""'· seonc'Fn(l ""'lino d,,. _,_,,.,,,, .. ,i-.,g a'1d ....-.,.,n1ng lOOdara """"'°· and cootplol'ng and ,.,.,...,g ,,.. "'°"'ll<n ol ""°""""""
The0'"'1•""" ,o '"'l>""" 0o .,. ""'""'1'°" ,. ""''""" to or,,- • """",;i "'""""""""" ...., ~et>!>e521v ~..,,, °""""'"" .. ...,.,,. "'nny
or E<!uco!oo, ,fOOM•ryt•od Avo , SW, "'"""""'°·
-i, ""l""'""l ""''""""'
,.,., ,,peel al'"" eorte<""' or """""'""'- 0-,,i ~lUQ"'°"" I<, rotlUcing!hi> l><lnl•n."'O.o IJ S Dcp""""'°'
O'\d ..
UC 1e2,o-•~' ., ""'""' l!.l!J<IO~ """ "''"'"""" Ot.lll Co- Numt,o, 1~45-XX>OI.,._, I'- ... ""' ,_m tt>o <"'"plot>d employmo ..
Co<lffltof;lo<, kff PloOk !lon,li;. ~ .. • Fo,glvonooo lo thO. odd,oo•.
N vo~ i..w •-"' or"°"com,•111otdl..., II>•"""" ot,.,... •~-ohlol •- oflhlo fom1. «1"'°<1 'I""' Dl<.e1 l<rffl ••""""' 1, .. Sociloo, 6)
PAGE 21 OF
~"ochrn<lf'I B - PSI.F S•nglo S~"'"'"' R<><1u;,..,.,..,1s Page 16,:,126

~O-FSA,Ct9-O,0014, faol< Qr,j9< OQO~
P<1"'1syl-,0•1o~
H")l'9< E~"'°"lloo """l"nc~ o¼or-qiPH(:AAJ
APPENDIX B
Jnstruaions for Reviewing an Employment Ceniflcat!on forin for PSLF
PAGE 22 OF EO-FSA-09--0--0014/022
lnslrucllons lo, R0\li<1w,n9 a PSLF Employm<lf't Cer111lcahonform (ECF)
Part 1 Bon-owu submlhl PSU' Emplovm•ntCertlllcatton tonn (Jll!Qllt1·2.,Se<.tlon, 1-3 ar11requlr11d) to

PSLF Servicer
s.,..,,,c,., sends iel!&r which.
11,,.
' NocIfte• botTowe, It,a! Iha ECF was r<>e<1ived
'I
' Oascnoos tha .,,uat ravl,iw arl(j m111nmvaudauon p,ocess, Including
,,'Checking thal tha funn'" complalely r.tled aot

Val1daling ,ampJoy,,r(s) as qua~ty,ng ~blic servIco orgarnza!;on(s) and that 1no fu~-nmo
I
'
emplo,m,anr ""!Uiremen! was mel
lri Matcn,ng quality,ng loan pll)'men1s tor tha1 p,,nod of """''°" i
C
'
Include" the ">peeled tumarouod time fur,,.,,;.,,,, (J0-60 days~ Additional ttmo may be neooss.ary II
,n!ormallon Is "''ss,ng o, requires add!bonal ravlew by servfoer or ED
0 Informs tho borrower of~oy program ellgIblhly rnqulmmoots a,-,d all Mr.t't'>""''Y dIsclosurns. ioclud1ng
roles and raspons,bolitl<ts or aH onUUes involved
,. Acknowledges that ser.1carwill retam submrtte<.I cert,ncahons o,n beha/1"

of lhe botTOW<J<
"'"' "'•.-..tear lrli".;, ,eview to et>.ck for co

STEP 1c Cll-!Kk th.at all REQUIRED informa!lan was provkled:
,, ---
Sed,on 1 lnformalion about the Borrowar Is complete (I.a,. SSN, name)
,, Section 2, BotTower sI9r,ed and datod the form
Sec110n3 (Employer):
" ,. (Item 1) Name. Address. EIN of the Organualion Is provided
(llem 2a) Stan Dataand End Dalo pro1Aded
"
iii. (11am2b) FuU-dm11sla1us checirnd The average hourn/Woek musl be provided,
,. or P~n-t,ma status cMcke-d. Tho averngo hoursMeol< must to p,ov>ded.
.
(Item 3) Ono bo• is checked (/or o--c) under Type or Public SeMco Organcz.alloo
IF (c) Is checked. one O<m<lffl typos ot public ,er.Ices mus! be cl1edced
• C"rMlcallon is comple1ed. iricludlng lhe Authorized Official's Name. Tille. Telephone
Numt,a,, Signature and Signa!ura OaIa.
,, Secbon 3-Alternate· If lhe 6orrowerchedcs lhe box under /nSffuctIOns /01 Bom,w9rwl>en "'"""' is
no Aur1>on1ed Offlcla/al lhe top of Sectkln 3. follow Ste1>1. Sec11on 3()-N) atJo,,e and requast
additional documentation thal suwons Iha borrower's cl;um of qual,tylng em1>1C>ymont
STEP 2: Hany ,n!ormatlon ,s altera,d, lhe Borrowar or Employer. as appropnate. must h3V6 W"1Itiale<lnoxt lo
the change. If U-a Borrow.or or EmplOyer hes no! inillaled tho altern1ion. re1um lhe ron-n
to lhe
botTOW<lC.
STEP 3: II InformatIon Is mlsstngc
1) You should a11empt to obtain tho m,ssmg lnformadOll beforn re1um!ng the form 10 Ille bO<Toweras
an mcomplele form, by conlacbnq Iha borro"""r or empkiyerby telephone o, 0-mad.
2) If no telephooe number or e-mail address was prnvlded, or you have atlemple<I wilhoul sucwss
lo reach Iha Inl<1nde<Jparty, retum lhe form to the boorower as Incomplele. In the letter. 1ndical0
specmc.llly Ml,ch rnform~l,on Is m,ss,ng and "'hat 1h11bo1T01Wrmusl do in order for the sar.,cer to
con~nue proc,ass>19 ttie form.
3) If a signature or s,gn,,CUre data IS missing In o,lha< Section 2 or J, rellJm lho form to lhe Borrowor. I
V tlorPSt.F
STEP 1- Check that the organization is Isled on 0O\I of lhe pm\/ided directories 'or each ,;atego,y, If 11Is not
round lll<rra. escalale lo lha Department. (Mailbox w,11ba prov,d0d by FSA)
F8deral, State. local or Trtblll govltfflment organlzatlon, ag..-.cy or entity·
hll.P//WWW uS8 govlAgenc•e"a shtml
Public chold or famdy ser.lce~ agoocy (run by st.a!eJoountylc,tyMt)al go,,,arnmenl)
Noto; Child and lomlly s6rvk:6s ogen;;:rcsth~t om non-pmlil 501(c)3 orqamza/IOns
(Car,.gasy B/ or priv.-t6 non-pm(/( 890"""" (Category C) ara also qual,fying under
PSLF
Tnbalcoll a0<un,V<1rs, M ·1Jww.N2!/<l o,,12oouv.n,tsn ~WMc/ Itta-tel th1ml
PAGE 2~ OF ED-FSA-09-0-00141022
All&cl'mOfl!El· PSlF s,,.,.r,, S•<vlcO< ri.,,,,,.,.,,,,.""1, Page 2{] a! 76

ED.f"SA-09-D-O(I 14 T""" 0roo< OOOS
Pe~.mt_van,a 1-'")h<>r~due-"""" A<;_,i;lanc~A PHF.AA
• /'Ion-profit 501jc)3 org,1nlu!lon, D.!)1!_~~ ,c:;_<J_<t~L~[tlp<J.1)-]J,'

Helpful hl"1s
• For Ocga,,,zabon Name, choose "Includes· ,n the dropdown manv.
• Search us,ng Iha organiza1ion·, 1vl name and chock ·A» of 11,e words" to narrow
lt>e sea,ct, I! negaUve ,.,,u11, CMdl !™I mganlzdlton·s ocrn~ym. or !he name
9xacUy as wnUen on l™I ECF
• Use tha orgJn,z;11I0,fs City arid Slate. as provided on 1h8 ECF
• A forelgr1 ,mll!y that Is reg,stara!Zal,on
quaI,r.,.s 11it ,s lourid hare. Se'8ci from 1flll ·coom,y· dropdown box
• Private organlzaUon pros<ding publ•c sGMCaS:

• If lhkSC<11'3'g(),Y oscMkad. Rr.i ~~arch lhe IRS database to see !I it Is oc1ually listed as
n,,v,r,g ~1/c)3 s!a!us.
, I/ NO. a3C31ateto°'" Depar1m9nl ror approval.
STEP 2. Cheek Full-Time slahm requoremen! (Sec8on 3, 11em21>)

• If Full-Time'" checked. hours must be 30or grealer II YES, condition Is met.
• II Parl-nme ,s checkt1d. lh<l borrower must provide add,Uooal ECFs forconcurren1 pa,,Ods of
employment for those months lo be qualifying (hou,s may be less lhan or greater 11\an30).
, To calculat,. ,r lwo or more Patt"Tlme pos,fons meet lhe Full-time rnq01renl(lnl:
~) Tho borrowe, musl svbmll cenJOca~ons lrom 1wo or morn part-t,me employers /or whoch
tho borrower concurtently worl<e<J.
b) Calculale tl1e totffl average weekly hours worl<ed,by adding lhe hoo,s provkled ,o
So~lion 3, Item 2b of eocil oortlflcatlon, next to Part-Time Wthe sum oflh<l ave,ag,o
hours Is 30 or more. lhe definilion of Full-Hme employee applies.
Jul. Aug. Sep.

Emp.
'""
"
,0
'
Fmp. rn rn
'
Total
hrs. <:
"
lO .lo
"
JO
"
30
; TOTAL" 30 hour1 perwooll lor Mao:11-July 2.0J1 g; monlha)
I Al reMt 30/JOUrn.lwmi-km1 MQUiN,dtor2 or 111(1,e par1.iwn..~?
I YESIO Full-llm• 1'9qUlramant utt.rlad 1w 5 montt..
I Proond 10 mnlthlrig months Ill"aua!iMna erflpjtr""'- w!lh tnll-.
E,r:...,.pla'2J
Employer 1: Pao1-umeal 3~ ~k during Fabru-,✓~r 2011 (6 monlhll}
• ""' '"" '"' '"" Pd ''" ,,., '" ., .,

Em"" 2.: PIW't-Um,:r
at 20 t~ durl~ ·AIXJUSI
2011-Mlifdl 2012 S fflOf'lhlJ
' 'Fob. Mar. Sep.
Emp.
,tmp.' " " " " " "

'
Total
,n.
" " " " " " " "
!
Greater uw, 30 houmfll,oeU as rtlQUir8dtor 2 or mo111
p.1:;;;_:c~:::0-cccc.,,-------,
No,,.,,ff.,. Iha bom>wff hi ...,plc:ryad lS h.........._t fnw-. f".tJrvaiy.JuJy llUI IM- employ.,
haa lnde.t.d that tlli, i. nm comldtnd full-H..... Whit. ltN ~ hu n1bmlu.d £Ch
from 2 parl-tlnw wnpl,ov--, i-..tuu then posltloN 1111 nol concumml ro, any glnn
c•nmr month, lhl Fult-d.,.. ,-quJ111mentI• not nP•ftad.
PAGE 24 OF ED-FSA 09-0-0014/022
A,Iacm1..-.:6 - PSLF Singlo SO<V>Gef Ro,qu,romoe!O p"'I" 21 ~r 26

EO·FSA,{.)'J-0-00H, hsl< 0,dnr00C5
P,..,,~,a H, "'Ed~ca1Ml<1Ass••ld•"'• " PHEM
; -~~!'.!..
4. Con1;:ll•~_rewiQWa~_malch quallfyh•g pa nls with ual •m o ..nt
S""EP 1 Once qual1f,ing employment ,s 0s1ablsh<1d,d9!enrnn9 1fqui0i1fy1ngpaymon1s ""'r,, rrade wnnln tnIs
penod
Count each month from°'" Start Date lo End Da1<1.v.fler9 a quallfyrng paym~t was ma<l8. For tl1e
.>ctual P<'Ym<>nt
•
first monlll the accual pavmoot dalo must t>oon or ~no1Ih0 St rt Dale For the la.i mo lh lhe
"
date must be t>efotollw End Date ol each Ernploymem Cer:lllcaUon Fo, Pan-um ..
emptoyoos. th8se cooe1,Uonsapply 10eadl employer.
. Fo, partial paym8n!:I made. Irle acIual paymwl date ,s the date on wh«h !he total of partial
paym9n1S aquals 10 or is greater Inan lhe full schedu/00 paym 6 nI du" amounl ror 11101
month
. Th" sche<!ul<ld payment dat" w,11<!etermlno 1110

coun1<><1.
caI,m<1armonth for which the ~ualfylng paymwt ,s
, ... Hotfflcatlon of
Example. Scheduled payment d<1lels J<1ly1 trut actual paynIent dale ,s June 29. Ass<1ming
lhe bom,we, does not have erevious d'"l~oonc19s, the gu<1h!),:1!!9J>avmenl
outc-
Send lhe Borrower a notlncaOon ot lh9 outcome of Iha re~.,w.
annl,oo to Ju~.
.
Fo, PSLF quallfylng employm•nt. the riobflcalkrn should includ" the followtng:
The borrowar"s loan,; 'MNbe transferred from the borrowers ony....,I se,vlu,fls} to, all federally held
. loans
Numb.,, of queltfylnQ paymenls made whde employed in qual>fytng public serv.:<1 (matched months),
. basad on the dates Indica1ed on tho current cortmcalion(s)

Tt,e total number of malched months the servicer has validated to dale end lhe remalfung number
requirad towards becoming <1lig1bl8for PSLF
• ..
Key reminders, ,ndudlng the (ollowrng:
Keeping cop"'s or submitted lorms and supportingdocumenls
Borrower must be employed In qual,fylng public sarvtce wnen applying for and ,eceIvIng
. /crglv<!MSS
Bnrrower musl apply for PSLF us;,g an ~pllcallon provided by the Oepanment aner having
. mot tM 120--monlh ellglbtl,ty fe<JUlfemenl

No partial forgiveness is allowed based on makmg le$,er lhan 120 qual>fying payments
• To reoolv<1any forglvooess under the PSLF Program most ol the loan payments must ba made
un<!e, IBR or ICR to have ~ny remaining roan balance after 120 pRymento nave b€-en mOOe
If unable lo validate PSLF quallfylng employmsnt. 111<1

nouncobon should Ir.cIudo the followrng:
. ..
lden11fythe spec,flc reason lhG ECF could not ba approved al this tim11
Missing roqu,red lnformallon (specify)
Unable lo conn rm employer ,s qualifying public serv,co orgarnallon (can sobmll i'dd,tional
. evidence)
FulHime requ.rnment {)(}\ me( (w,11 r11-evaluale if addHlonat ECF"s are submlltad ror tt,ls period
..
of public se,vice employment)
flleglblll (specify) or crossed out/altered 1nlormaOoowr!houl inillal5 of 001ender
The borrower"s federally held loans wiW1emain w,lh the borrowe,"s original servicer until a v~lid
ECF Is submitted.
.• Key rnmInders. •nctudlng tho following .

I
I
. Keeping copies ol submitted forms and supporting documenls
Borro"'1r must be employed In qualtfy!ng pubIic service when applying tor and rece,v,ng
I
. rorgiv-ss
Borrower mus I appfy for PSLF using an app/ical1on prooided by th<! Department afler heving I
.. me! 111e120-monlh eig,bll,ly requlrem.,nt

No p~rll,.. /orgiv<S!ness•~ allowed based on making IP%<1rthan 120 qoal1fytng pa~ments
To receiv" any forg'"eness under the PSLF Program mos\ of lhe loan paymenls mcrst be made
undo, IBR or ICR to have anv rema,n !CAA baolalnce after 120 pa=nts nave bean made
Part6 Cortlllcatlon trom Am$11Co .......,.

STEP· 1: Flag Employment Certification$ re<=elv,odImm bom:>wern wt,o a,elwere AmenCorps or p.,ace Corps
volunteers for lumi, sum payment el<Ceplton.
If an Amer.Corp,, or Pe>ICfr~•
!M""
.,,,1un1...,, m!ld" quahlylng payments dlJring the period o~:MO"I
quaijfylng payments shculd be matched following rmrmal prowdc,ras.
I
If uali ng payment• wan, !'~_il!~da_~~!!!l!_~ penod of servrce look !or a ,ump SU'!' en!.
PAGE 25 OF EO-FSA-09·0-00 141022
Altocllrn0<1IS - l'Sl~ S,nq•• S<,,y~er Roqu,n,m,,n(s P,'lge 22 ~1 2!;

EO-FS/\-09-0-0014 Ta,J,, Oro<,, 00<:5
Ponm;~~~lgMr Fd<Jc.aU<mAs..,siaoca A7"nq, (PHFAAJ
I I • 1r t>Olump sum wa• rocelve<j con~ct 11>$borrcwar rammding homltler 1t>a!mak,ng a lump
sum paymenc from a Sagal award or traos,tion ll1lfmM1 ~an be applied as PSLF-
qual,fy111t,1
payments
If a lump sum J13yman1is r&eeM>d~rrom !ha Na~onal Servu:e Trust for AmanCorps. and
sum a, quanfy,r<;J
witt,/n 6 months or tne E~d Oaie tor Pa...-;<,Corp,.__,,ppry tna 1......,p
pJyments, as allowed ,n tha regula1!ons
STEP 2- Maten Ing cradl!ed qualrfy,ng payments to AmeriCorps/Peace Corps 39,v100
Start from the las! s(NVlce month for which thc,re 15no cormspondlng QtJallfytngpayments and proceed
backwards up Co 12 m<;m!hs
E.,,rnple: BorrQWflr submits an ECF from tile Peace Corps Mlh seJVlce da1as January 15, 2012-
November JO. 2013. du~ng which time his OJract Loons W<!reon a Pe11ceCorps deteflnent
Borrower subm,ls" luml' ~um paymen1 lo serv,oe, In lhe amount ot $5000 1Nota only lhe ma.rmum
transition award should ba considered for th,s lump sum conversion-------<:urrenlly$7,425). P,oymant
was ,_ved Jooua,y 10, 2013, wothinthe allowed 60 days. Tne borrower', monlhly payment 'NOUld
haoa been $200.
$50001$200~ 25 monltl!I. Although the borrower was 111 service tor23 mon1hs. Iha ma,,mum nlXlll>er
of Quallfyinq paymenls (QPs) tha borrower m&y recervo credit for Is 12,
These QPs m,i[(:h wllh 12 mooths ol qualifying emplo)'ffi8nl, stallfng w•lh Nowmber 2013 !o
Oet<3mber 2012. Use th& 1~ day of the monlh when record,ng credrted OP date (e.g., 11/01113,
10/01113. etc.). II a credit Is applle<.fto lhe s1an Oa18 moo!n, use tha Start Data (e 9. 01/15/12 ,r 51art
mon1h was one or Ille 12 crooked OP months).
·u an ECF Is received w~h Peace C-Orpscarllfica~on, 00 oot reJoct for PSLF allgl.b,Htydue !o no OPs
un1il the 60-dB)'wlndow Ms e~ired.
Nole on 11.manCorpsSegal Awanls:
Amer!Corps Segal Award payments do 001 ha,e a 60-<lay from End Dale payment requlreme111.A oolunlear
has 7 rs aner service ro a Se al Award.
PAGE ?6 Of' EO-F SA-09·0-001410?2
An..:hmenl B - l"SLF Sltlgje 5qrvl<w R<>qWB"""'t,; Pag~ 2J ol M

EO·FSA--09-0-0014. TasJ,. Om,.. 0005
P.,.,.-..javarae H,q,_ Educalion """"'•nee Age.-.:.,.WHEAA)
,_
Ena)oc!•
<•,.not be
=•ladlro"1
..dillngflold
••• DEPARTMENTl/SE ON!. 'f
OfU(J<Al. RECEoPTCIATI1: ....
,_, "" •a.$·'='
,,...
,,_,
.... o .. , "'''"""'
/Nsmu,;noNS FOR COUPLETING A,..D SUBlrffTTWG THtS EJIPI.O'f/llENT CERT/RCA TJON

Po"" .... •~l""'.I
<nU.O>'9n,.., "-"•
~.,.....
.,
th,.
'""""'""'"
kxm In S"-""" 7
'9'. and dole s.,ction l •~Y '"""'"""""
,., """""'"g
.,,. ..,
,c~d
--h<•••f<kl In Soctlo<,o 1 0<1.
f_..--,
"'VI'"'""""
....,,,
om-om~
r,..,
yo,,,,,........... _,.... -• ooy
'-" '""" """C "'"""'
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cru,_,,.,
hlad< '""
oo,np1ej<iy.. .,,,.
5,,,;:'""l.-.u,I
tr, bo
Yoo
[SECJION I: BORROWERKJENTIFICATION
P180M ocitm o, C<Jm>ctI"" fcil<f'Mn9ln!orw.a!fon
1 ',SN L.l......LJ . LL..J
:Z10Codo
r.,o..,/,ono- "'""'""---~-------------
SECrlON 2: BORROWER'S CERTIFICAflON REOUEsrs. AUfflORIZArlONS, AND UNDERSTAND/NG$

Befa,... sl11nH111, carefully read tha en/Ire form, Including the Instructions and accompanying letter.
I reqU<1sl that ltl11U.S. Oepaftment of EducaUon (Iha Oopartmen!) accept this Empk>ymanl C81111k:ationImm !he public service
organiiadoo at which I amlwa5 employed for purposee of qoallfy1r,g for !ha Publk: SaMce Loan Forg,veries, Program. 1ft sutimtt
lhls form befo111I am ehgtile to apply fOf fo'9"'aness, I request lhat 1h11Oepartmen1 reta,n this original certificallon lo+"mumll I
subm,t lhe App!Icabon Jor Publ>CSen,ic;e Loan F0<91veness.
I au!horir.e my 8mJIIOyer(s) or 01h01ent,Ues having reconJs about the employment that Is pert ol lhe basl!I for my re-quest for
lorg,veness to make 111fonna11on from lhose recon.ls available to !he De11artrnenl, ncll.ldIng my Dlro.:t Loan ser,oc,ir I also au!ho,ize
rt,,, IJ S Oepartmem of Educabon and ,ts respectJ\'e aganls and conlraums. lo conlacl me regarding this €m11loymenI C6rtlftcalloo.
at lhecurrenl Of any future numbar lha1 I prov1<111 tor my caltulllr lelaphone Of OU'l&rw~ele.ss d""oce using automated telephorie
d,ating equipment or artificial or pre,ecorded voice or te)rt messegeg.
I unde"tand ltlat:
(1) t may only quuI,fy for PuDOc Service loan Forgt...eness an&r l ha\/8 made 120 separate, qoalrfyIng monlhly payments on an
<11191ble01rec1 loan. aller October 1, 2007. while employed !ull-Uma by a public servlca organizaUon(s). or sen,lng In a full•lime
AmeriCorps or Peace Corpe posIllon. "' accon:lance w,lh lhe deOnlUoos ,n Secllon 6. These 120 peymenls do n01have to be
consocu1,ve:
j2) I must be employed full-lime bye public serv,oa organlzanoo(s) or "'"'""9 •n a full.time AmaoCorps or Peace Corps pos,t,on al
the 1,me I apply for loan f0<giveness .v>d a1Ih11limo the forgoven,,,ia Is granled. I may be employed part.lim,, concurrently by
more It,,.,-, one eig,ble publ,c sen,lce organization and moo1 tha 11.'il-llmerequ~emont:
(3) Only Ille remain;ng balance of my k>an(s) after I )lava made Iha 120 separate. qualifying monthly paymenl!I and met all o1her
""g,bmty reqwremanl!I ol lhe PSLF Program may be forgiven:
(4) 1 am nol required to submit any Employment C6r11HcaOon(s)before applying for looo torgl\/8ness. bul ,fl do, the Department w,~
review each Emµloym,mt Cart.Ocadon I submit 10ensure Iha! 11el compI01e. will ver,ty lha1 my employerqua!,lles as a pubt>C
service organiza~oo. and lha1 lhe loan paymants Imada durlng ltla perlod covered by the Employment Cert,l'k:abon(s) are
qualrfy1r.g paymen1s. fonow,ng lh•s review, the Oepartmemw,11 nobly me In wrlUng of Iha number of qualllylng paym"'1ls I have
made while employed ,n qurrhfymg public seMca and the remaming number t must make before I am eligible lo apply fo, PSLf.
I will also be no11H&din wrlUng ,t the Ooparlmenl datem..nes Iha\ 1he fonnfs) I subm,ned Is ,n~~l<>le or Iha! my employment
does not meet the qualifying crileria under Iha regula~ons. Including lhe reason(s) for the detenninallo~s). along w,lh lhe steps I
would need 10 take to complete ttn form or correct this Information: at>d
(5) Tha O..par1ment ,.;11only detennme wt>ether I h""e tulAled 311of the requlfflments lo be el,g,ble for PSLF a~e, I hase made a~
120 qualifying pa~nts and have subm1!18dmy loan f<xglveness applo;ano" ! unden;tand lh~t lh& law doas not p&m11Ipa,r1,a1
forg,veness based on ma~irig a les..,rnumber or quaify1r,g monlhly ~ayments while 'M':lrl«ng ,n qualllying pubilc service
REOUIRFD REQUIRED
Sl!JROltln of l!orrnwer Dal9 {MM-00-'fYYY}
PAGE 27 OF ED· FSA·09-0·00 14/022
Atl,rl,mmi 6 - PSt.~ S-<1gloSar,.•lte, R"'IUKO,,.,.nl•

ED-~ SA .00.D C-014, ra.. oroo,0005
>'oon•)"IY""'a 11,glw Edll<"_,,_ A"""'",ce Agency iPHEAA)
,..,.,...,, No,..,
Outto-,s5" l_L·...Jr I 'L.-LLLJ
SECTION J: Ct:RTIFfCATTON OFEIIPI.O\o'lff'NT
, .. O«flo.,,. 1 al ,.. acc ....... .,..,g
'"""""'"''Co""""'""' Emt,10,,._,
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PAGE 28 OF EO·FSA·09-0-0014/022
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ED FSA-00-0-l-.014, hs.l Omar 000$
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APPENDIXC
SAMPLEPSLF REPORT
PAGE 29 OF ED-FSA-09-D-00141022
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PAGE 30 OF ED-FSA-09-0-0014,'022
, 1 Con1ract ID Code
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT I
, 2. AMENDMENT
'
MODIFICATION NO 3 ffFECTIVE DATE 4 REQUISITION/PURCHASE REQ
NO I 5 PROJECT NO. (1f ~pplicab!e)
'
023 1 DEC 02, 2011 ''
, 6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If o1her lhan item 6) CODE
' Uruted St.ites Oepartmenl er Educa1,on I
I Federal Sludent A,dM,ss,on Support Group See Block 6
630 Forst St NE - Su,1e 91F3
Wa~honglon DC 20202
l-.,c"c"a7,coao,M~========="°"""'"'",;ccc.7,cc,=~==7,===~--~~-~=~====~~======~----I
8. NAME AND ADDRESS OF CONTRACTOR (NO., Street Country, State and ZIP Code) (,) 9A AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103 1--
1200 NORTH 7TH STREET Cage Code. 41UK?
0, 0. D"A"T"E"o=1s"E"E"l'TE"M=,
1--., 0,,~--------'
II
! W-FS~ 09-C-'.XIH I
X i
10B. DATED (SEE ITEM 13) I
CODE 0003077 4 j FACILITY CODE JUN 17. 2009 I
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICIT A TIO NS
:D Toe abo1,1enumbered solic1tatiori is amerided as set forth in item 14. The hour arid date specified for rece1p1of offers D is extended, 0 Is not e~tended.
Offers must acknowledge receipt of 1his ameridmerit prior to the hour and date specified in the solic,!ation or as amended. by one of Iha following methods.
! (a) By completing 1\ems 8 and 15. and returning ___ copies of amendment: (b) By aclrnowledging receipt of this amendment on ead1 copy of the offer submit1ed:
or (c) By separa1e letter or telegram which includes a reference to the solicitation arid ameridment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER . If by111 rtueo mI e .su chhc angemay be ma d e b y teegramor
Isamen d men your d esire oc hangeano ffer area d ysu b'ttd I Ill
e er.pro \11dd ch
! teleQram or letter makes reference to the soticilatlon and this amendment. and is received r rior to the oneninn hour and date snecified. ' "
12 ACCOUNTING AND APPROPRIATION DATA (If required} Modification Amount. $0_00
'
Mod1ficat1on Obligated Amount: $0_00
· See Schedule
Check One A THIS OROER 10 ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MAOE IN THE CONTRACT
I
ORDER NO. IN ITEM 10A.
i
! THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes In paying
B
office, appropriation date, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43_103(b)_
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

X Mutua( agreement between both parties.
I
D OTHER {Specify type of mod1fication and authority)
E_ IMPORTANT· Contractor IX is not, r is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENTIMOOIFICA TIDN (Organized by UCF section headings. 1ndud\Jlg solicilabonlcontract subject matter where feasible)
he<>pl as pro"1ded herein, all terms and cond;~ons of 1t-..doCt.Jrnenlrafemnced In <tern 9A or 10A. as h6re!ofore cl)sogod. remo;n, unct,angcd end in lu~ lorce and effect_
i~N'°\f>.1~ AND TITLf OF ~NER (Type or print) 16A NAME AND TITLE OF CONTRACTING OFFICER (Type or pnnt)
:\ \ [j~)2,v'-.,ID _ ?:M.., :N1cholasChung
- _ 1202-377-3635 nicholas_chung@ed gov
l i[Jrrl;
\~6·~&tmEROR 15C DATE SIGNE 8. UNITED STATES OF 16C_ DATE SIGNED
,----------
'I b)(6) DEC 02, 2011
(Signature of person authonled to sign) Si nature of Contract111

NSN 75-IO-Ol-152-80i0 STANDARD FORM 30. (Rev. I0-83)
Prel'iuu~ I-edition unusabl~ Prescnhe<l by (iSA l·,\R (~ll (TR) ~1 2-U
Supplementary Page
Description of ModificationfAmendment:
The purpose of this modification is to incorporate the following five (5) Two Factor Authentication (TFA)
Tokens in addition to tokens previously provided under Modification 021. Tokens are being issued as
Government Furnished Property in accordance with the terms and conditions identified under this contract.
The tokens provided to PHEM under this modification have the following serial numbers:
AVT848655190
AVT848655204
A VT848655229
AVT848655237
A VT848655253
PAGE 2 OF 2 ED-FSA-09-0-0014,023
1
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1 con1racllDCode
2. AMENDMENT MODIFICATION NO 3. EFFECTIVE DA TE 4. REQUISITION/PURCHASE REQ NO. i 5. PROJECT NO. (if applicable)
'
024 1 DEC 08, 2011 !
, 6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (U other lhan ,tern 6) CODE
, Ur,1ted States DepMment of EducatHJn
F9<leral Slude~I A,dtM,ssmn Support Group See Block 6
I 830 f.rst SI NE - Su1e 91FJ
I Wash,nglonDC 20202
I
· 8 NAME AND ADDRESS OF CONTRACTOR {NO, Street, Country. State and Z!P Code) 9A. AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103
1200 NORTH 7TH STREET
Cage Code: 41 UK7
HARRISBURG PA 171021444 98. DATED (SEE ITEM 11)

ED-FSA--09-Cl-0014
X
D The above numbered sol,clta1ion Is amended as set forth In Item 14. The hour and date specified for receipt of offers D is extended, Dis not exterided
Offers mus! acknowledge receipt of this amend men! prior to the hour and date specified m the solicitation or as amended, by one of the follow,ng methods:
{a) By completing items 8 and 15. and returning_·-· copies of amendment. (b) By acknowledging receipt of this amendment on each copy of the offer subrni1ted;
or (cj By separate letter or telegram which includes a reference to the solic,ta~on and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR ANO DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER. If by virtue of this amendment your desire to charige an offer atready submitted, such change may be made by telegram or leUer. provided each
telenrarn or letter makes reference to the solic1la1ionand !his amendment, and is received nrior to ttie onerung hour arid date specified.
12, ACCOUNTING ANO APPROPRIATION DATA (If required) Mod1fical1on Amount: S0.00
Check One A THIS ORDER ID ISSUED PURSUANT TO. (Specify auttiorify} THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in p;,ying
office. appropriation date. e1c) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103/b) I
I X a mutual agreementof parties.
D OTHER (Specify type of modificalion and authority)
'
E. IMPORTANT: Contractor I 1s not, [xis required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENOMENT.'MODIFICATION (Organ.zed by UCF section headings, including solicilationlcontract subject matte, where feasible)
Excapt as proolded harei,,. aN le,ms and cond,Mn• <'.I/Ihadocum8"( ralarer,ced In ,!ef'! 9A o, 10A. as nere1olora CMnge<l, remain, Lnc:llan aM n foll force and eflecf
15A. NAME AND TITLE OF SIGNER {Type or print) 16A. NAME ANO TITLE OF CONTRACTING OFFICER (Type or print)
\ \ -\ \\·\ ;; \-,. :)'')·() MikeWhisler
i ' ' · ~ \_'- rnike.whisler@ed.gov
':- , ' ' k, ' , i ',,, 'I
__.!_~~-CONTRACTOR/OFFE OR 15C. DATE SIGNED 16B. UNITED S TES OF. MERICA 16C DATE SIGNE □-
(b)(6)
(b)(6)
DEC 08. 2011
(Signature of person authonzed to sign)

, nature of Contractin
NSN 7540"0l-l5H\070 STANDARD J,"OR..l\t30. (Re,. 10-lU)
Previous F<litw11 unusable Prcscrihc<l by GSA F,,R (48 CFR) 53.243
Supplementary Page
The purpose of this modification is to incorporate the following terms and conditions for the Special Direct
Consolidation Loan (SDCL) Initiative:
(1) Attachment A - SDCL Terms and Conditions (1 Page)

(2) Attachment B - SDCL TIVAS Requirements ( 15 Pages)
(3) Attachment C - SDCL Incentive Plan (3 Pages)
The terms of this modification replace and supersede the terms of Modification 020 created under this
contract. Funding obligated via Modification 020 shall be utilized to support operations incorporated in this
modification.
PAGE 2 OF 2 ED-FSA-09-D-0014i024
Attachment A
Special Direct Consolidation loan Initiative (SDCL)
PHEAA · Task Order 006
Federal Student Aid
Objective
The servicer shall satisfy the requirements (provided as Attachment B) for the Special Direct
Consolidation loan Initiative (SDCL).
Pricing
Price per Borrower (SSN)Consolidated: A borrower with a valid SDCLApplication (Promissory Note)
from the Direct Loan origination and disbursement system and completed transfer and load of one or
more eligible Federal Family Education Loan Program (FFEL)loans. Invoicing may occur upon successful
completion of one or more loan transfers.
Price per Borrower (SSN} Consolidated

Unit low Unit High Price
0 150,000 $ b)(6)
~
150,001 300,000 $ ~
300,001 400,000 $ f-
400,001 UP $
The units above reflect cumulative borrowers consolidated over the course of the program. Once a
threshold is achieved/surpassed, all volume in the next tier shall be invoiced at the corresponding rate.
Period of Performance
January 1, 2012 through December 31, 2012.
1 of 1
SDCL TIVAS Requirements: Eligibility Attachment B
Requirement Clarifications Validation Artifacts

A borrower is eligible for the Special Direct Consolidation Loan if at least one of their ED-held
loans is
not in default (or 270 days or more delinquent), and that borrower also has a commer
cially held FFEL
100.00 !that meets the eligibility requirements to consolidate.
Although borrower eligibility factors may fluctuate over time, the TIVAS is ultimately accounta
ble for
tracking those factors, ensuring only eligible borrowers participate, and ensuring only eligible
loans are
100.01 consolidated under this program.
Eligibile commercially held FFEL loans must be in repayment, deferment, forbearance, or grace.
100.02
Defaulted commercial loans (defined as technical default, "270" past due) are not eligible for
100.03 consolidation.
Defaulted ED held loans ("270" past due) may not be counted toward the one (1) ED held loan
100.04 qualification re_guirement.
TIVAS are able (and encouraged) to work with a borrower to "cure" (defined as less than 270
days
overdue) at least one technically defaulted ED held loan in order for them to be eligible for this
100.05 program.
For program qualification purposes, loans held at TPD do not count toward borrower qualification
for this
100.06 I program.
101.00 IJoint Consolidations will not be offered under the Special Consolidation initiative.
102.00IED-held loans cannot be consolidated under the Special Direct Consolidation
Loan program.
TIVAS shall make a final determination of borrower eligibility based on LVC data received
from loan
holder prior to submitting a Loan Purchase Claim File to FSA. However, FSA reserves the
right to
disqualify any loan from participation in the Special Direct Consolidation Loan program should
new
103.00linformation come to li9ht.
Page 1 of 15
SDCL TIVAS Requirements: Eligibility File Attachment B
Validation
Requirement Clarifications Artifacts
200.00ITIVAS shall be able to accept and process a weekly NSLDS eligibility file.
200.01 I Weekly file will be a complete snapshot (not changes-only) of all eligible borrowers in NSLDS
database
assigned to that specific JIVAS.
TIVAS shall receive the eligibility file through the existing NSLDS adhoc message class (AHSLDE
OP.)
20002
TIVAS shall receive the eligibility file from the TG box from which NSLDS receives TIVAS
loan submittals.
200.03
200.04 FSA shall distribute the files on Friday evenings.
201.00[Error handling for the eligibility file shall be resolved manually between TIVAS and
NSLDS should List of organizational
problems arise.
contacts for error
resolution
202.00ITIVAS shall identify weekly changes in NSLDS eligibility file and adjust borrowe
r communications
accordingly.
202.01 TIVAS shall contact borrowers already in the process of consolidation who lose eligibility for
the program
to explailll_he apQlication'.§_curren_!statusL as well as how to reqain eliqibility to participate.
202.02 TIVAS shall notify borrowers already in the process of consolidation who lose eligibility for
one or more
loans (_butretain (2_[Q_Qram__filigibilitil
of tha_tloan's loss of ~Ii _,L,..
Page2of15
Attachment B
SDCL TIVAS Requirements: Borrower Counseling & Communication

Requirement Clarifications
FSA intends that, in accordance with the announcement, TIVAS promote the
I Validation Artifacts
special direct
consolidation loan opportunity to all eligible borrowers.
300.00
300.01 Promotional efforts are to be conducted within FISMA boundaries.
Once a loan is consolidated under this program, TIVAS shall send borrowers
a disclosure ("Welcome Copy of
letter") to provide loan amount, interest rate, repayment schedule, and other
pertinent information (e.g. correspondence
process for adding/removing loans from the app, first payment date, etc.).
(follow existing
nonstandard
communication review
request process)
301.00
ln cases where there is no consolidation, the disclosure shall notify the borrower
that no consolidation
301.01
occurred. I
TIVAS shall begin to process the application immediately once it is received
, and contact the borrower
regarding application processing issues. There will be no hold/rescission period
(10 day or otherwise)
302.00[applied to applications in this program.
Applicants will get a notification from studentloans.gov after the successful submiss
ion of the application
that provides information on how to contact his/her servicer in order to cancel or
remove one or more loans
302.01 \ from the application.
TIVAS shall provide FSA a copy of all formal communications materials to borrowe
rs for review and Copy of
approval.
correspondence
(follow existing
nonstandard
communication review
303.00 request process)
Page 3 of 15
Attachment 8
SDCL TIVAS Requirements: Borrower Counseling & Communication

Reauirement Clarificatians Validation Artifacts
TIVAS shall provide one bill for all loans to the borrower.
Sample bill
demonstrating a
single bill for all ED
held loans, showing
304.00 payment instructions
Page 4 of 15
SDCL TIVAS Requirements: Application AttachmentB
Requirement Clarifications Validation Artifacts

TIVAS shall be able to accept incoming electronic applications for this program
via new file types on Adhoc report
the LDE.
showing records
400.00
loaded/errored
Message classes will be:
CNASPQOP - CPN Request File (Production)
CNASPCIN - CPN Receipt File (Production)
CNASTQOP - CPN Request File (Test)
400.01 CNASTCIN - CPN Receipt File (Test
400.02 Application files will be sent to TIVAS' existing TG mailboxes.
Error correctionwith COD shall be handled manually;no systematicprocessfor error
correction/reloading
400.031 is requjred.
TIVAS shall add/remove underlying loans (upon borrower request) to an in-proce
ss application
401.00lwithout needing to amend the promissory note.
At borrowerrequest, TIVAS shall be prepared to remove loans or cancel the consoli
dationaltogetherup
until the day that the FMS Purchase Funding Request (also know as Loan Purchas
e Claim File) is
401.01 submitted to FSA. I
Borrowersshall use a Federal Direct ConsolidationLoan Request to Add Loansform
to add loans within
403.01 I 180 days of the con,;olidation.
402.00JTIVAS shall provide customer service support post-application.
403.00ITIVAS shall add loans to a completed consolidation for up to 180 days
after consolidation.
Borrowersshall use a Federal Direct ConsolidationLoan Request to Add Loansform
to add loans within
403.01 180 da~ of the consolidation.
TIVAS shall providethis paper form (or a PDF link on their website) to the borrow
403.02 er.
A repayment plan selection shall be required prior to completion of consoli
dation under this program,
404.00ithough selection is optional on the application itself.
404.01 I TIVAS shall obtain a selection from any borrower not completing this elemen
t on the application.
In cases where the TIVAS has conflictingrepayment plan informationfrom the borrow
er,current
commercialloan holder(s), and/or the TIVAS' own servicingsystem, TIVAS shall reach
out to borrowerto
404.021 det!)rmine the most appropriate repayment plan.
405.00JTIVAS shall counsel and place borrowers on the most appropriate repaym
ent plan for them.
Page 5 of 15
SDCL TIVAS Requirements: Application Attachment 8
Requirement Clarifications I Validation Artifacts

In cases where traditionalloan consolidationis appropriate,TIVAS shall also counse
l borrowersabout this
405.01 alternative.
If a borrower selects a repayment plan that may be inappropriatefor his/her circums
tances(for example,
selecting standard plan when the applicant is currently on IBR), the TIVAS shall reach
out to the applicant
to determine the appropriate repayment plan.
405.02
In cases where the borrower has not selected a repayment plan and the borrow
ercannot be reached, the
TIVAS may place the borrower in the repayment plan that applies to the borrower's
405.03 current ED-held loan.
If the borrower selects IBR or ICR, with notice to the borrower, the TIVAS may tempora
rily place the
borrower into the repayment plan that currently applies to the ED-held loan, pending
405,04 receipt of the
In keeping with 34 CFR 685.208, the TIVAS are to apply the same repayment
plan to all the Direct
406.00\Loans including the new Direct Consolidation loan from the Special
Direct consolidation.
In the event a borrower selects a repayment plan which one or more of their ED
held loans would not be
eligible for, TIVAS shall contact the borrowerto resolve the conflictand ensure the
above requirement is
406.01 met
Exception: In cases where the underlying loan was a Parent PLUS loan [which is not
eligible for IBR], and
IBR is selected as the main repayment plan, the borrower can be on two differentrepaym
406.02 ent plans.
In the event a borrower chooses a repayment plan that is not consistentwith the
Direct Loan(s) held by
the TIVAS the TIVAS shall contact the borrrower and verify if the borrower still wants
the new repayment
plan. If yes, the TIVAS will move the Direct Loan(s) to the new repayment plan.
406.03
TIVAS shall collect and maintain information documenting eligibility of borrowe
rs selecting IBR or ICR
407.00las a repayment plan.
If the borrower already has a loan on IBR or ICR, no new documentation needs
to collected in support
408.00 Iof their repayment plan selection for the new consolidation loan(s).
TIVAS shall leave the borrower in an IBR status using the LVC information and shall
collect
documentationat the next recertificationdate, which will be included on the incomin
gLVC (Partial
408.01 Financial Hardship Renewal Date). I
Recertificationof the borrower'seligibilityfor IBR shall occur on the borrower'sestablis
hed recertification
408.021 date.
Page6of15
SDCL TIV~~ Requ~~ments: Loan Creation
I Attachment B
Requirement Clarifications ·-~~~
r ~ \Upon receiVing application vi3 studerllloans.gov, TIVAS shall research additional loan • • ·· · ·• • ·••- · ·'
details
soo.oolwith commercial lenders and_further clarify applicant's ellgibility.
TIVAS shall send an LVC request for any loans being consolidated to the commerci
al loan
501.00\ holder.
501.0l]TIVAS Shall use -either electronic or paper formats when communicating with lenders.
TIVAS shall receive and process incoming LVC information for the Special Direct
1) Welcome letter to student showing total balance, interest rates,
Consolidation Loan, including (but not limited to) the following data elements repayment schedule and plan (mocked up data based off LVC scenarios
on the
underlying loan: provided by FSA):
2) Sample bill demonstrating a single bill for all ED held loans, showing
payment instructions
502.00
LVC shall report current interest rate, bi'!Tancedata, IBR information, repayment
plan information,
502.01 I and number of days overdue.
TIVAS shall apply the .25% interest rate reduction to the current rate reported by
the loan holder
502.021 when recordin~ the loan.
TIVAS Shall apply an additional .25% intereSt rate redllction for borrowers enrolling
In electronic
502.031 ~ebit on~ny loan,
As there will be a gap between the lender's LVC certification date and the anticipated
sale date,
50 2.04 1 TIVAS shall calculate anticipated interest balance as of sale date and ·include that ·,nthe payoff
Fees on the underlying loan shall be capitalized into the principal balance of the
new consolidation
502.05! loan.
Deferment data: (1) Type of Deferment or Forbearance and (2) Ending date of Current
Deferment
or Forbearance These two new data fields shall be completed if the 'Loan Status
Code' indicates
502.061 that the loan is in deferment or forbearance.
The neW consOi'1dat'1on lo3n shall retain the Same defe"rment or forbearance status as its
502.071 underlying loan.
At the 'end date of the current deferment or forbearance. the servicer shall reach
out to the
borrower and follow normal servicing procedures for either extending or ending the
borrower's
502.081 deferment or forbearance.
When recording the new loan on TIVAS servicing system, the "begin date' for any
existing
502 .09l deferment or forbearance shall be reset to the date the loan 1sconsolidated (sale
date).
S03.00/Loans for which no LVC response has been received cannot be consolidat
ed.
If a lender does not return the LVC within 10 days, the TIVAS may proceed
with the
504.00iconsolidation of the loans for which an LVC has been received.
The TIVAS shall contact the applicant to let them know that a loan will not be included
in the
consolidation because the loan holder has been unresponsive The loan may be
added later, that
504 .01 I is, within 180 days of the consolidation provided the lender responds.
New consolidation loans on the TIVAS servicing system should be booked
using one of the
. existing consolidation loan type codes for direct loans (D5, D6, D7.)
505 00I
I
L I
There will be no grace period hold for the Special Direct Consolidation
506.0Q consolidate ~ill lose any grace period(s) on their underlying loans.
Loan. Applicants who
Page 7 of 15
SDCL TIVAS Requirements: Purchase Attachment B
Validation
TIVAS shall set the sale date for each deal and communicate that sale date
immediately to both Copy of
600.00llender/servicer and FSA correspondence
TIVAS shall create a FMS Purchase Funding Request and submit to Financia
l Management System Copy of FMS
(FMS).
Purchase Funding
Request containing
deal info provided to
601.00
ITIVAS during testing
601.01
TIVAS shall submit purchase deals as frequently as daily, and no less frequent
ly than weekly.
601.02I TIVAS shall submit FMS Purchase Funding Request to FMS at least 3 busines
s days prior to sale date.
Example: For a Friday sales date, TIVAS would be expected to submit FMS Purchas
e Funding
601.03 Re@est no later than 1Oam of the preceding Tuesda
601.04 TIVAS shall transmit files using the existing SAIG (PFUNDGIN) message class
and mailbox.
601.05 The FMS Purchase Funding Request shall use the new transaction type: "SCN".
TIVAS shall create a FMS Purchase Funding Request and submit to FSA Busine
ss Operations Copy of LPDF
containing deal info
602.00 provided to TIVAS
602.01 during testin
TIVAS shall submit the Loan Purchase Detail File at the same time that the FMS
Purchase Funding
Request is submitted.
602.02I
TIVAS shall submit the Loan Purchase Detail File via the same email channel
to FSA Reconciliations as
used for the CONDUIT proQillm (to FSA Reconciliations).
602.03I TIVAS may mixlenders and servicers intoone Deal, and one loan detail schedul
e. (Note: FSA has
attached an example Deal Reconciliation and Loan Detail Schedule to these requirem
ents. In the
columns of the detail, separate columns are reflected for the lender/seller and
the servicer. In addition,
the summary at the top provides for subtotals.
602.04I TIVAS shall send a copy of the Loan Purchase Detail File to each lender/servicer
(roster), ensuring that
only the appropriate subsections are deliv~red tQ each l~nder.
_ TIVAS shall not be required to submit a Bill of Sale as part of this program.
603 001
Page 8 of 15
SDCL TIVAS Requirements: Purchase Attachment B
Validation
TIVAS shall report the Credit Reform Code on the FMS Purchase Funding Request and FMS
Summary
File for the new consolidation loan being booked, using existing rules for CRC calculati
on.
604.00' ·
Page 9 of 15
SDCL TIVAS Requirements: Lender Payoff Attachment B
700.00IAII Treasury payments under this program will go directly to the loan holder.
TIVAS shall assume that a purchase will be completed when the sales date has been
reached, unless otherwise contacted by FSA (no later than 1 business day prior to sale date.)
700.01
Upon completion of a purchase, TIVAS shall book all purchases for a given day with
DISBUR transaction and note on their next daily summary file using the new loan program
!Sample FMS Summary File (tested as part of 1ST)
701.00lcode value: "SCN"
The Credit Reform Code reported on the FMS Summary File shall reflect the CRC of the new
701 •01 1 Ioan program. I
Sam pe
I FMS Summary •·i1e (t ese
I d aspa rt oI IST)
TIVAS shall be prepared to halt booking and summary file reporting of any loan deemed
701.021 ineligible for purchase by FSA.
TIVAS shall maintain a tab within the current PUT LOG for SDCL deals, and a second tab
702.00ltor SDCL adjustment deals,
The !og shall be submitted weekly (using current practice, one cumulative log with multiple
702.01 tabs, reoresepting all act'lv·1typlanned and executed
Page 10 of 15
Attachment B
SDCL TIVAS Requirements: NSLDS Reporting
Requirement Clarifications Valldatio_ri_Artif~cts ~13:ed_ed
TIVAS shall report each new consolidation (D5, D6 and D7) loan to NSLDS.
All requirements in this section shall be
demonstrated by a successful NSLDS reporting
800.00
file (part of IST1
TIVAS shall report all applicable record types and fields required for reporting a new loan
,to NSLDS
801.00
802.00(TIVAS shall report specific fields with the same data applicable to the underlying loans.
TIVAS shall report the NSLDS Unique Label of the underlying FFELP loan (originally
803.00lcreated by NSLDS) to NSLDS on the new consolidation loan.
In cases where the loan did not previously exist on NSLDS (e.g. added by borrower), NSLDS
803.01 \ un·1gueLabel will not exist and T!VAS may leave that field blank when reportin,
TIVAS shall create an Award ID for the new consolidation loan for reporting to NSLDS,
using updated Data Provider Instructions.
804.00'
TIVAS shall report a new Program Code indicating the FMS program code via the Loan
B0S.00 1Record Type.
TIVAS shall report any new repayment terms made as part of the consolidation via the
806.00!Repayment Record Type._
TIVAS will report all new consolidation loans on a given Promissory Note with the same
807.00IMPN ID via the MPN Record Type.
TIVAS shall report any loans added to the consolidation up to 180 days after the
808.00lconsolidation has completed.
Page11of15
Attachment B
SDCL TIVAS Requirements: Reconciliation and Over/Underpayment Process

TIVAS shall include loans under the new loan program code (SCN) in existing month-end
900.00lreconciliation reporting (2a - 2d and 2n - 2g reports).
Wherever existing reports break data out by loan program, TIVAS shall add the new loan
900.01 I orogram to the structure of the report.
SDCL loan volume shall not be included in any of the operations reports (ie. the 21 reports
referenced in file attachment 1100A_Dl_OpsRpts_v1 .1.zip provided to TIVAS as part of
ECASLA PUT Phase 3 requirements). No changes to these reports are required at this
901.00lume.
TIVAS shall provide a new report (TIVAS Consolidation Operational Report) in support of
902.00\the SDCL program.
TIVAS shall report SCDL program data on a separate TROR from other loan programs.
903.oo·
TIVAS shall follow existing deal reconciliation requirements, providing a "Principal &
Interest Servicer-to-FM$ Receivable" reconciliations for all deals.
904.00
These reconciliations shall explain and support any differences between dollars requested in
the loan purchase file and dollars booked on the servicing system through the DISBUR
904.01 transaction.
Deal-by-deal reconciliations shall be submitted using existing submission time-frames and
904.02 .transmission channels established for the CONDUIT program.
In cases where the loan holder has been underpaid by Treasury, the TIVAS shall submit a
"mini" deal for the underpaid amount, just as they did for the original deal (submit via the
loan purchase file and report a OISBUR transaction on summary file.)
9os.oo·
These transactions shall be associated with the original DEAL so that reconciling items are
905.01] resolved.
ln cases where the lender has been overpaid by Treasury, the TIVAS shall bill the lender
for payment if the TIVAS becomes aware of the overpayment prior to being contacted by
906.00lthe lender.
906.01 l TIVAS shall use REX to accept return of excess funds by lenders.
A SUMDEP transaction shall be sent lo FMS by the Servicer (via FMS Summary File) when
906.02J a payment is received.
The Servicer shall also send FMS either a PUTRET or COLLEC transaction (see below) to
906.03[ .§.Qolythe collection to the correct loan and reverse the original overpayment transaction.
Page 12 of 15
Attachment B
Proper usage of FMS accounting transactions related to overpayment adjustments is as

follows: If a payment was received on or prior to the date of consolidation, and that
payment was applied by the lender so as to reduce the balance of the account, then the
proper FMS transaction is PUTRET (an adjustment to the purchase price). If the payment
was not applied to the borrower account (i.e. held in the lender suspense account for
some reason), or was received after the date of consolidation, then the FSA receipt of the
funds is a COLLEC (1.e. the lender has forwarded borrower misdirected funds to FSA).
906.04
TIVAS shall collect this information from the lender at the time that the !ender notifies
906.05 TJVAS of overpayment, and generate the appropnate FMS transaction.
Over and underpayment tolerances for loans consolidating under this program shall
match FSA's June 28, 2011 Electronic Announcement.
(http:J/ifap.ed.gov/ean nou ncements/062811 DirectConsolidationloanlnfoU nderpymtsOverp
907.00lvmts.html).
DEAL tolerance differences shall be handled through Principal & Interest Adjustment
907.01 transactions jADJPRI / ADJINT}.
907.02 Adjustment transactions shall tie back to the loan being adjusted.
TIVAS shall include activity related to the SDCL program on the FMS WIPfTXlfTXO file,
908.00ltouowing the revised instructions provided by FMS on 11/17/11,
Page 13 of 15
Attachment B
SDCL TIVAS Requirements: Incentive Pool

TIVAS shall be prepared to accept additional performance-based loan transfer
volume from ACES via the EA 27, using the existing business process governing
the
onboarding, servicing, and reporting of inter-servicer transfers.
1000 00
For applicants split between one TIVAS and ACES, the transfer of ED held loans
from
1000.01 ACES to TIVAS shall occur after the consolidation is completed.
TIVAS shall be prepared to support customers during the time that the borrower
is
1001.00lsplit between ED servicers.
TIVAS shall promote the Special Direct Consolidation Loan program to all borrower
s
1002.00lin their assigned incentive pool.
Page 14 of 15
SDCL TIVAS Requirements: Additional Requirements Attachment B
Requirement Clarifications Validation Artifacts Needed
·TIVAS shall add a process flow for this program to their existing A-123
1100.00ldocumentation. Updated copy of A-123 flow(s)
TIVAS shall provide management reports indicating results of promotional efforts

1101.00lincluding, but not limited to, number of booked loans on a weekly basis.
1102.00ITIVAS shall work with FSA and trading partners to develop a sp_ecific 1STschedule.
Page 15 of 15
Attachment C - Special Direct Consolidation Loan Program Incentive Plan
PLANSUMMARY
Under the Special Direct Consolidation loan (SDCL)Program, the TIVAS will market the SDCLprogram to
borrowers who are within the TJVAS'individual portfolio and meet eligibility requirements to participate
in the program. The purpose of this plan is to incentivize the TIVAS to maximize consolidation bookings
under this program, by providing an incentive pool where the TIVAScan earn additional borrowers
eligible for this program, but held by a non-TIVAS servicer (ACS Education Solutions under the Common
Servicers for Borrowers contract). Under this incentive plan, the TIVAS can earn additional volume
beyond those borrowers currently in their individual portfolios, transferring those borrowers to the
TIVASthat successfully consolidates the loans, giving that TIVASongoing servicing rights to that
borrower in accordance with the terms of the TIVASIDIQ contracts.
This incentive plan will reward the TIVASbased on demonstrated successof their campaign to the
targeted and eligible borrowers for this Special Direct Consolidation Loan opportunity.
GOAL OF THE INCENTIVE PLAN:

Create incentives to encourage the TIVASto effectively reach out to eligible borrowers to
consolidate under this opportunity.
Create incentives to encourage the TIVASto counsel the borrower on selecting a repayment plan as
part of the Special Direct Consolidation loan process. counsel
Ensure full distribution of the incentive allocation pool of eligible borrowers.
INCENTIVE REWARD
Upon consolidation (that is, a Direct Consolidation Loan is booked), the TIVASwill begin to service the
loan(s) it holds for that borrower even though the borrower is in split status. All ED-held loans of the
borrower who consolidated under the Special Direct consolidation will then be transferred to the TIVAS
that completed the consolidation for that borrower. The transfer of loans will follow the normal
transfer process currently in place for resolving split borrowers. At the end of the process, the TIVASwill
have all the Direct Loans for that borrower who consolidated under the Special Direct Consolidation
opportunity. The Government estimates that the incentive pool may contain between 500,000 to 1.4
million total eligible borrowers.
DETAILS
Process:
Metric will be calculated on February 15, 2012 based on a snapshot in time of borrowers who have
completed an Application/PNote by February 14'h 11:59PM.
The incentive allocation pool wm be distributed with the first weekly NSLDSeligibility file after
March 1, 2012. Please note: No transfer of loans will occur until a Direct Consolidation Loan is
booked.
As noted above, there will be no additional file for the TIVASto process as part of this incentive plan.
1 of 3
Each TIVASwill get a portion of the total award of borrowers based on the performance metric
normalized (see calculation and example below)
Performance Metrics Calculation:
• Metric 1: Cumulative% of Eligible Borrowers Participating in This Program - Weighted 90%

• Metric 2: Cumulative% of Eligible Borrowers Participating in This Program Who Selected a
Repayment Plan on the signed Application/Promissory Note - Weighted 10%
• Metric 1 and 2 will be combined to determine% to normalize
Metric 1 Calculation:
Formula (Cumulative% of Participation):
Total No. of Borrowers with Signed P- Notes
-----------~~----- X 0.9X100
Total No. of Eligible Borrowers Assignedto the TIVAS
Formula (Cumulative% of Repayment Plan Selection);
Total No. of Borrowers with RepaymentPlan Selection on Signed P- Notes
==~-~=~ =~==~-==~~~=~~-=~ K 0.lKlOO
Total No.of Eligible BorrowersAssignedto the TIVAS
Metric 1 + Metric 2 =%to normalize to determine% of incentive allocation pool to distributed to the
TIVAS.
EKample:
SAMPLE: 300,000 total borrowers to be distributed
TIVASl had 100 total eligible borrowers to reach out to, of whom 40 submitted promissory notes and 20
selected a repayment plan at the time of submission.
Performance metric calculations for TIVASl:
40/100cc0.4 X 0.9 = 0.36
20/100=0.2 X 0.1 = 0.02
0.36 + 0.02 = 0.38xl00 = 38%
TIVA52 had 200 total eligible borrowers to reach out to, of whom 20 submitted promissory notes and 5
selected a repayment plan at the time of submission.
Performance metric calculations for TIVA52:
20/200=0.1 X 0.9 = 0.09
5/200=0.025 X 0.1 = 0.0025
0.09+0.0025=0.092Sx100 = 9.25%
2 of 3
TIVAS3 had 100 total eligible borrowers to reach out to, all of whom submitted promissory notes and 50
of whom selected a repayment plan at the time of submission.
Performance metric calculations for TIVAS3:
100/100=1 X0.9 = 0.9
50/100=0.5 x 0.1 = 0.05
0.9+0.0S = 0.95x100 = 95%
TIVAS4 had 300 total eligible borrowers to reach out to, of whom 100 submitted promissory notes and
25 selected a repayment plan at the time of submission.
Performance metric calculation for TIVAS4
100/300 = Q.33 X 0.9 = 0.30
25/300 = 0.08 X 0.1 = 0.008
0.30+0.008 = 0.0308x100 = 3.08%
Normalization Calculations
38% + 9.25% + 95% + 3.08% = 145.33 %
Since 145.33 does not equal 100%, the metric needs to be normalized to determine the distribution of
incentive allocation pool.
Normalize to 100 % to determine the percentage of the total incentive allocation pool to distribute by
dividing by 145.33.
100/145.33 = .69
145.33*0.69 = 100 %
Multiply each performance metric by 0.69

TIVAS1- Performance metric= 38•0.69 = 26% of ACSportfolio
TIVAS2 - Performance metric= 9.25*0.69 = 6%of ACSportfolio
TIVA53- Performance metric= 96"'0.69= 66% of ACSportfolio
TJVAS4- Performance metric= 3.08*0.69= 2% of ACSportfolio
Assuming an Incentive Allocation pool of 500,000 borrowers:

TIVAS1 earns 130,000 additional borrowers (26% x 500,000) to whom to reach out to.
TIVAS2 earns 30,000 additional borrowers {6%x 500,000) to whom to reach out to.
3 of 3
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1 1 Contractiocode

;
I 2 AMENDMENT \100IFICATION NO. 13EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ "JO ' appli,;;,.,ble)
PROJECT NO (if
' 025 JAN01,2012 I'
I
' 6. ISSUED BY
UMed Stal<>sOeoa,im,.nl of Educat,o~
Federal SIudent A,d/MissronSuppo<1Group
CODE FSA-FS2 7 ADMINISTERED BY (If olhor than item 6)
See Block 6
CODE
1
830f.r,tSttJE•Surte91FJ
I Wash,ngtonDC 2U2'J2
i i
I8 NAME ANO ADDRESS OF CONTRACTOR (NO .. Street. Country, State and ZIP Code) 9A. AMENDMENT OF SOLlCffA TION NO.
! HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA DUNS: 007368103 1,1 I
' 1200 NORTH 7TH STREET Cage Code: 41 UK7
r-- '
' FINANCIAL MANAGEMENT 5TH FLOOR
'
98 DATED {SEE ITEM 11)
!
i
'' X
ED-FSA--09-0-0014
i
' CODE 00030774 I FACILITY CODE JUN 17, 2009
!
D The above numbered solicita~on is amended as set forth in item 14. The hour and date specified for receip1 of offers Dis extended, Dis not extended
Offers must acknowledge receipt of this amendment pnor to the hour and date specified in the 50licitation or as amendsd, by one of the following methods:
(a) By comploting items 8 and 15. and returning ____ copies of amendment: (b/ By acknowledging receipt of this amendment on each copy of the offer sub milted;
or {c) By separate le1ter or telegram which includes a reference lo the solici1ation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE !
YOUR OFFER If by virtue of this amendment your desi1e to change an offer already submit1ed, sLJchchange may be made by telegram or letter. prov,ded each
1ele ram or teller makes reference lo the solicitation and this amendment, and is received rior to the o enin hour and dates ocilied.
, 12 ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: 0.00
' See Schedule Modification Obhgated Amount: $0.001
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/OROERS. JT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER ID ISSUED PURSUANT TO· (Specify au1horily) THE CHANGES SET FORTH IN ITEM 14 ARE MADE lN THE CONTRACT
II B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES {such as changes in paying
office, appropriation dale. elc} SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b).
i
C THIS SUPPLEMENTAL AGREEMENT IS PHEREO INTO PURSUANT TO AUTHORITY OF !
X a mutual agreement of parties.
I
' D OTHER \Speciry type of IT'Odifica!ion and au1hority)
i
E. IMPORTANT: Contractor I is not, Ix is required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings. including solicitation/contract subjecl mailer w~.ere feasible)
hCO!JI as prov.Jed Me,em_ all len"s and Cond•bons o! lt,e OOcumeN referoncoJ In ,1em 9A Of 10A M M<elohr,, cMang~d. rem~lns unchwQed and ;n lull !o,rn and e~ec't
15A NAME ANO TITLE OF Sl,GNER (Type orpnnt) ~ I 16A. NAME ANO TITLE OF CONTRACTING OFFICER (Type orprin1)
; , ,,j i i Mike Whisler
' • ' ' : mike.wh,sler@ed gov
'
(b)(6)
(b)(6)
DEC 08. 2011
(Signature of person authonze<l to sign)

(Signature of Contracting O(ficer)
NSS 7540-0 l-152-8070 STA'>iDARD H)RM 30. jRev. 10-113)
l'rcvHlus F.d,uon unusable Prescribed by USA FAR (48 CFRi 5D4J
Supplementary Page
The purpose of this modification is to incorporate the attached Default Aversion Pilot Program (Attachment
A). This Pilot Program applies for the period of performance identified within Attachment A only, and does
not replace or change any other performance metrics currently incorporated into the agreement.
PAGE 2 OF 2 ED-FSA·09-D-00141025
Attachment A- Default Aversion Pilot Program
Default Aversion Pilot Program
The Default Aversion Pilot Program will be established to add further focus on effective borrower
counseling, delinquency prevention, and default aversion. A quarterly incentive pool of $1.2 million will
be established with each TIVAS receiving up to $300,000 per quarter based on their performance against
established baselines. Performance will be measured on a quarterly basis, with incentives awarded
after the end of each quarter. The following metrics will be used to assess performance:
Performance Incentive Metric# 1 - Percent of Borrowers in Current Repayment Status -

Calculation = (count of borrowers in current repayment status at the end of current period)
divided by (borrower count of all borrowers in both current and delinquent repayment at end of
current period).
Performance Incentive Metric# 2 - Percent of Borrowers> 90 Days Delinquent - Calculation =

(borrower count of borrowers> 90 days delinquent at end of the current period) divided by
(borrower count of alt borrowers in both current and delinquent repayment at end of current
period).
Performance Incentive Metric# 3 - Delinquency Resolution of Borrowers Delinquent> 180 days

- Calculation = (count of current borrowers (<=30 days delinquent) at end of period who, in
prior calendar quarter end had a delinquency of 180 days or>) divided by (count of borrowers
>=180 days delinquent at end of prior quarter).
Performance on each metric will account for one-third of the incentive payment; with a quarterly
incentive pool of $300,000 per vendor, each TIVAS could earn up to $100,000 per metric per quarter.
The goal of the incentive is to drive continuous improvement. A TIVAS showing improvement over the
same quarter for the previous year on a given metric would earn $100,000; a firm that does not improve
compared with the baseline would not receive an incentive payment.
Q1 Q2 Q3 Q4 Total
Metric Number 1 $100,000 $100,000 $100,000 $100,000 $400,000
Metric Number 2 $100,000 $100,000 $100,000 $100,000 $400,000
Metric Number 3 $100,000 $100,000 $100,000 $100,000 $400,000
Maximum incentive
amount $300,000 $300,000 $300,000 $300,000 $1,200,000
Period of Performance
This Default Aversion Pilot Program shall be in effect from January 1, 2012 through December 31, 2012.
1 of 1
1 Contract ID Code
2. AMENDMENT MODIFICATION NO, 13EFFECTIVE DATE 4, REQUISITION/PURCHASE REQ. NO.
' I 5. PROJECT NO. (11applicable)
r,~=== ___ 0_2_,

_____ =="-=o_E_c_o_9~,
2_0_1_1_-+-~-E~o~o_,_s_A_-1_2_-0_0_0_0,_s
___ ~-~~--------'
6 ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (llo1her than item 6) CODE
Unoted S1a1es Depamren1 ol Educat,on
Federal Student A,d/M,ss,on Support Group See Bloc!<: 6
630 F,rst SI NE - Su1t891FJ
Washington DC 20202
8. NAME AND ADDRESS OF CONTRACTOR (NO, Street, Country, Slate and ZIP Code) 9A AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS 007368103
(X)
1---
! 1200 NORTH 7TH STREET Cage Code: 41 UK7
~-c-~~~~~-----------

ED-FSA.W.04114
X
108. DATED {SEE ITEM 13)

D The above numbered solicilation is amended as set forth in item 14. The hour and date spec,fied for receipt of offeffl O Is extended, Dis not extended
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solici1ation or as amended, by one of the following methods·
(a) By completing items 8 and 15, and returning ___ copies of amendmenl; (b} By acknowledg,ng receipt of this amendment Oil each copy ol the offer submitted:
or (c) By separate letter or telegram which Indudes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DA TE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each
telMram or letter makes reference to the sohcitat,on and this amendment, and is received I rior to the o=nino hour and date s=cilied.
12 ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount· $8,250,000.00
Modificalion Obligated Amount $8,250,000 00
See Schedule
Check One A. THIS ORDER 10 ISSUED PURSUANT TO. (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
!
office, appropriation dale, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103{b)
1
D OTHER {Specify type of modlficahon and authority)

X Funding only.
~-~MPORT ANT· Contractor I is not. l'Xis required to sign this document and return 1 copies to the Issumg office.
I 14 DESCRIPTION OF AMENDMENT/MODIFICATION (Organiled by UCF section headings. 1nduding sohcitation/contract subject matter where feas,ble)
'
E~cep1 as prnvlde-d Mre,n. al lerms and con<Jltlnnsol !t-.e cloa.Jmenl referenced n'\,tem 9Aor 1()A, ao ~erolobla manged, ramain• uncMnged and In IIJIIfo«:e ao;I effect
15A NAME AND TITLE OF SIGNER (Type or print) 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
°', ', t"\:- . , , ~ "t. Nicholas Churlg
• c , · ' •. • .. '< - 202-377-3635 nicholas chung@ed.gov
I
'-=~•='==~"'-~' =='==·•_c'~~cL,'~\'.r I \ : ! (
~B..:SONTRACTORIOFFEROR __ ------J 15C
• .' f ; ,\ ( " I .
DATE SIGNED 16B UNITE
/
OF AMERICA 16C DATE SIGNE-□·- --1
I
i
I
rb)(6)
-
I
1
, ,/
I/2j /2
0 I(
I
(b)(6)
',========~-/
,_"lltC ,., ,011
I
i
i (Signature of person authori:zed to s,gn) , 15 nnature of Contractmn
I Officer' i
NSN 7510-01-151"8070 STANDARD FOR\130. (Rev. 10..j,13)
Previous Edition urrn~able Prescnb...xlby {JSA FAR (.J8CFR) 53.143
Supplementary Page
The purpose of this modification is to add funding in the amount of $8,250,000.00 for operations and system
enhancements. The new not-to-exceed contract total is increased by $8,250,000.00 from $102,869,578.10
to $111,119,578.10.
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND

PAGE AMERICAN
2 OF FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
3 ED.FSA-09-D-00141026
1-----~----
-------------·----
----
C_on
-s-C-i-teD___
_u_L iinu;d-·-
_E --~------- -----·--·· ---···7
------.--
---~-~~
I~~
!~: :;-;_;:~·-::II-:=J-=
7 '-----+-'
__
--+--
: :.I-1--·-·
UNITPRIG
__•_
-
._
IAccounting and Appropriation Data:
I
i°202A2012.B 2012 ENB00000.6CA 2521A.AB5 000.0000 000000
, $8,000.000.00
1· I
\ FOB Destination
I
l
(New Line Item)
0016 Funding for Title IV servicing system enhancements.
1.00 i SE 250,000.00 250,000.00
i Accounting and Appropriation Data:

0202A2012.B.2012.ENB00000.6CA.2521 A.AAJ.000 0000 000000
$250,000.00
FOB Destination
!
I
l_ ---- l__ ___ -~------- -----
PAGE 3 OF 3 ED-FSA-09-D-00141026

I 2. AMENDMENT MODIFICATION NO. i 3. EFFECTIVE DATE •
''
REQUISITION/PURCHASE
I 1. Con1ract ID Code
REQ NO ! 5
i - ,-,
Page of Pages
PROJECT NO . {If applicable)

---
3
........
' 027 DEC 22, 2011 EDOFSA-12-000116 !

6. ISSUED BY CODE FSA-FS2 ADMINISTERED BY (II other than rtern 6) CODE
United Slates Departmert1 of Edue81lon
F-ral Studem A;d/Mlssl<)(l Sup~rt Group
'See Block 6
830 Forst St NE - Su,te 91FJ
Walih,nglon DC 20202
i
Jula Jones '
8 NAME ANO ADDRESS OF CONTRACTOR (NO. Street. Country, State and ZIP Code) 9A. AMENDMENT Of SOLICITATION NO.
(,)
I HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103
CageCode:41UK7
~

9B. DATED (SEE ITEM 11)

EO-FSA-09-0-0014 '
X
10B. DATED {SEE ITEM 13)
CODE 0003077 4 I FACILITY CODE JUN 17, 2009
D The above numbered solicitation Is amended as set forth in item 14. The hour and date specified for receipt of offers D
,s extended. Dis not extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of the following methods:
(a) By completing items 8 and 15, and returning ___ copies of amendment: (b) By acknow~dging receipt ol lhis amendment on each copy of the offer submitted:
or (c) By separa1e letter or telegram which indudes a reference to 1he soliciladon and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. If by virtue of this amendment your desire to dlange an offer already submitted. such change may be made by telegram or letter. provided each
letemam or letter makes reference to rhe solicitation and this amendment and is received onor to the ooenino hour and date sMcified.
12 ACCOUNTING ANO APPROPRIATION DATA {lfrequ,red) Mod1ficat1on Amount' $5.000,000.00
See Schedule
Modification Obligated Amount $5.000,000 00
' Check One A THIS ORDER ID ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying
-
' office. appropnalion date, etc} SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
c. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

' X Mutal agreement between both parties
I
i I
i '
E IMPORTANT: Contractor I is not. D<is required to sign this document and return 1 copies to the issuing office.
i
I 14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF secilon headings, including solicitatioll/contracl subjeci matter where feasible}
E><cepta• pn,"ded here"1, al terms and condibons uf !1'18documenl referenced "' ,tem 9A or JOA.as ~erelolore changed. rema4ns unctraoged and In fu! force end affoct
16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
Nicholas Chong
1
202-377-J635 nidlolas.chung@ed.gov
FFEROR NITEO STATES RICA 16C DATE SIGNED

✓
• rb)(6)
(Signature of person aulhonzed to s'Qll)

S nature of Contr
r-;sN 7540-01-152-8070 STANDARD FORNI JO. (Rev. 10-83)
Pn:vious Edition llnusablc Prc~cribcd h) C.SA FAR (,JS CFR) 53.2-13
Supplementary Page
The purpose of this modification is to add funding for Special Direct Consolidation Loan (SDCL) operations.
Total funding vatue of this contract and all modifications increased by $5,000,000.00 from $111,119,578.10
to $116,119,578.10.
All other terms and conditions remain unchanged and in full force and effect.
PAGE 2 OF 3 EO-FSA•09·0-00141027
SCHEDULE Continued
ITEM NO. SUPPUESiSERVlCES QUANTITY UNIT I UNIT PRICE $ AMOUNT$
(New line Item) !

Acquis1t1onPlan Request Number FSA000060
0017 Funding ror Special Direct Consolidation Loan (SDCL) 1.00 SE 5,000,000.00 5,000.000.00
operations.

4253XNOYR.B.2012.ENBOO000.A16.2521A.AAG.000.000.000000
$5,000.000.00
FOB: Destination
I
-----~---~---- -~I
PAGE 3 OF 3 ED-FSA-09-D-0014/027

1. Contract ID Code r~ne1
of Panes
I ,
2. AMENDMENT MODIFICATION NO. 13.EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ. NO. 15.
PROJECT NO. (if applicable}
028 JAN 19, 2012 EDOFSA-12-000119

6. ISSUED BY CODE FSA-FS2 7. AD~INISTERED BY (If other than i!em 6) CODE
Un~e<i States De!)artment ot Education
Federal Student Aid/Mission Support Group See Block 6
830 F;rst St NE. Su,te 91F3
Wash,ng!on DC 20202
Juna Jones '
8. NAME AND ADDRESS OF CONTRACTOR (NO .. Street, Country. State and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO
(X)
~
1200 NORTH TTH STREET
Cage Code: 41UK7
HARRISBURG PA 171021444 9B. DATED (SEE ITEM 11)
i
ED-l'SA--09-0-001l I
X '
0 The above numbered solicitation is amended as set forth in item 14. The hour and date specified for receipt of offers D
is extended. Dis not eKlended
Offers must acknowledge receipt of this amendment prior to the hour and date specified in (he solicitation or as amended. by one of the following methods: 'i
(a) By completing items 8 and 15, and returning~~- copies of amendment, (b) By acknowledging receipt of this amendment on each copy of the offer submitted: I
or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
tele ram or letter makes reference to the solicitation and this amendment. and is received rior to the o enin hour and dates cified.
12. ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: 13,000,000.001
See Schedule
Modification Obligated Amount: $13,000,000.00·
'
Check One A. THIS ORDER ID ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
8. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying
office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43103(b}.
X Mutual agreement between both parties.
E. IMPORTANT: Contractor r- is not, r5<is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF secUon headings, including sol1c1tatron/con\ract subject matter where feasible)
as ~°"1ded herein.all t<mnS an(ern9A or 1OA. as MrelO!o<e t:nanged, rema1es unchanged and in full force and effect
E«:epl
15A. NAME AND TITLE OF SIGNER (Type or print) I 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
: Nicholas Chung
·202-377-3635 nicholas.c ov
11I\ (/ ""'
··-- )6C DAfE SIGNED
/ JAN 19, 2012 i

I
NSN 7540-01-152-lWI0 S IA.~DARD FORM 30. {Re~·. 10-83)
Previot1s Edition unusable Presrnhcd by GSA FAR (48 CFR) 53 24.1
Supplementary Page
The purpose of this modification is to add funding in the amount of $13,000,000.00 for operations and
system enhancements.
Total funding value of this contract and all modifications increased by $13,000,000.00 from $116,119,578.10
to $129,119,578.10.
All other terms and condtions remain unchaged and in full force and effect.
PAGE 2 OF 3 ED-FSA-09-D-00141028
SCHEDULE Continued
ITEM NO, SUPPLIESJSER\IICES UNIT PRICE S
------
QUANTITY
"" -
AMOUNTS
--
j
(New Line Item)
Acquisition Plan Request Number FSA000069 '
0018 Funding for Title IV Servicing. ' 1.001 SE ' 13,000,000 00 13,000.000.00

0202A2012 B 2012.ENB00000 6CA.2521A.AB5.000.0000 000000
$13,000,000.00
FOB. Destination '
1
'
i
i
'
I
'
'
' '
I
'' '
'
'
I
'
''
·- ·-~---····---··-·- L.
PAGE 3 OF 3 ED-FSA-09-D-0014/028
I
1
contractiocode I£~~0 o!pfl:~--
'I 2. AMENOMENT MODIFICATION NO. 13.EFFECT!VE DATE 4. REQUISITION/PURCHASE REQ. NO. 15PROJECT NO. {if applicable)
029 JAN 27, 2012
6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other lhan item 6) CODE
Urnted Slates Departmeol of Education
Federal Student A1diM1ssion Suppor1 Group See Block 6
830 Firs! St NE - su,1e 91F3
Washington DC 20202
Jul,a Jones
8. NAME AND ADDRESS OF CONTRACTOR (NO., Street, Country, State and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103 ~
1,1
HARRISBURG PA 171021444 98 DATED {SEE ITEM 11)

ED-FSA-09-0-0014
X
D The above riumbered solicitation is amended as set forth in ,tern 14, The hour and date specified for receipt of offers Dis eXlended. Dis not e~terided.
Offers must acknowledge receipt of 1his amendment prior to (he hour and date Sf]ecified in the solicitation or as amended, by one of the following methods;
{a) By completing ~ems 8 and 15, and returning ___ copies of amendment; {b) By aclmowledglng receipt of this amendment on each copy of the offer submitted,
or (c) By separnte letter or telegram which includes a reference to the sollcilation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. II by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, pro111dedeach
teleqram or letter makes reference to the solicitation and this amendment, and Is received r,fior to the o=ninn hour and date s"eclfied.
12. ACCOUNTING AND APPROPRIAT!ON DATA (If required) Modification Amount $-100,000.00
Modification Obligated Amount: $-100,000.00
See Schedule
Checi< One A. THIS ORDER ID ISSUED PURSUANT TO. (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE !N THE CONTRACT
I
8. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE AOMINISTRA TIVE CHANGES (such as changes In paying
X office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
i C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF·
D OTHER (Specify type of modification and authority)
E. IMPORTANT: Contractor I is not, Ix is required to sign this document and return

' copies to the issuing office.
14. DESCRIPTION OF AMENDMENTIMODIFICATlON (Organized by UCF section headings, indudmg solicitation/contract subject matter where fea~ble)
Exceplas provkl&dherein.all \ennsandcond1!1ons

of the OOCUITl<!lll
referencedt,, i1em9A or 101\,a, here1olore
,;:hsnged.
remainsunchan[ledatld ,n Jul forceoodeffect
15A. NAl',,1EANO TITLD ?3NER LType or prinl) Ii
16A. NAME AND TITLE OF CONTRACTING OFFICER {Type or pnnt)
\l[A\f£ "'-! 0:'.&J '- 1Nicholas Chung

1202-377•3635 nicho!as.chung@ed.go1r
!
\1v,?rt:Cf::/Y\ \)(W'1,r~N\/aJ'lS,,rJ,c,i:C,
158. CONTRAOU»RJOFFEROR i 15C DATE S!G:t::!J:D 1 16C DATE SIGNED
(b)(6)
b)(6) i ,
,
I ;
' - ,
---
I
JAN 27, 2012 ;
i (Signature of person authorized to sign) '' ~

IS,1111ature 00 ctinr, Officerl Ji I
1',;SN7540-01-\52-8070 ,~NDAIUl H)RM JO. ( Re,·. 10-liJ)
PreviolL~Edition unusable Prescribed by GSA l'AR /.l8 ('FR) 53.7.43
Supplementary Page
The purpose of this modification is to de-obligate $100,000.00 funded under Modification 020 for Special
Direct Consolidation Loan (CR 1550) start-up cost.
Total funding value of this contract and all modifications decreased by $100,000.00 from $129,119,578.10 to
$129,019,578.10.
All other terms and conditions remain unchanged and in full force and effect.
PAGE 2 OF 3 ED-FSA-09-D-00141029
SCHEDULE Continued
IT1'.M NO. SUPPLIES/SERVICES I QUANTITY UNIT UNITPRICE I AMOUNT$
(Changed Line Item)

0014 Funding for Loan Consolidation Initiative. 1.00 SE 0.00 000
0202A2011.B.2011.ENB00000.6CA.2521A.AAJ 000.0000 000000
$0.00
FOB : Destination
~~~--'----------------------------~_ PAGE 3 OF 3 EO-FSA-09-0-00141029

! 1 Contract ID Coda r!lg:
--,
f--~gr_~f
2. AMENDMENT MOOIFICATION NO. 3. EFFECTIVEDATE 4. REQUISlflONIPURCHASE RED. NO, 15PROJECT NO. (ifapphcable)
030 MAR 06, 2012 !
'
6. ISSUED BY
u,111.,~Sl~tes Oopartmont orFdccai,on
coos FSA-FS2 7. ADMINISTEREDBY (If olher\han item 6) COOi'.:
F&Ceral St'1doot Aid1M,ss,on S~pport Group See Block 6
830 Fiest St NE - su,te 91F3
Wnsh,n~too DC 202C2
Jw,a Jooes 202,377-4263
8. NAME AND ADDRESS OF CONTRACTOR (NO, Street, Coi.:ntry, State and ZIP Code) 9A. AMEt-.DMENTOF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY, PEN"ISYLVANIA DUNS: 007368103
(,)
~
12C0 NORTH 7TH STREET Cage Code: 41UK7
FINANCIAL MANAGEMENT5TH FLOOR
HARRISBURG PA 171021444 98. DATE:) (SEE ITEM 11)

EO.FSA-09,D.0014
X
D The above numbered solicitation Is amended as set forlh In item 14. The hoor and date specified for receipt of offer5 0 is extended, Dis not extended.
Offers must acknowledge receipt of this amendment p~or to the hour and date specified in the solicitation or as amended, by one of the following methods:
(a) By corrpleting items 8 and 15, and returning ___ copies of amendment: (b) By acknowledging receipt of !his amendment on each i;opy of t'1e offer subrr.ilted;
or (c) By separate letter or te1egram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. If by virtue of this ame~dment your desire to change an ofer already submitted, SI.IChchange may be made by telegram or letter, provided each
tel=ram or letter makes reference to the sol1cita:ion and this amendment, and is received nrlor to the ooeninn hour and date snecified.
12. ACCOUNTING AND APPROPRIATION DATA (If required} Modification Amount: $0.00
See Schedule
Check One A. THIS ORDER ID ISSUED PURSUANT TO. (Specify authority) THE CHANGES SET FORTH IN lTEM 14 ARE MADE IN THE CONTRACT
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying
X office, appropriation dale, etc} SET FORTH iN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b}.
C. THIS SUPPLEMEITTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF;

'
'
D. OTllER (Specify type of rl'odrncation and !luthortty)
i-------·· ·-·-···-
E. IMPORTANT: Contractor IX is not, I Is required to sign this document and return copies to the issuing office.
14, OESCRIPTION OF AMENOMENT/MODIFICA TION (Organized by UCF section headings, including solicitaticn,'oon!ract subject matler where feasible)
E~cepl as pro.,,dad ~om·n i,11tffrms ,nd r.ard''<>rs cfth<l doromen( re1er.,nced In it,m, SA or ·oA. as oar"1ofilm ci1an~ed ,emains unchanc,><J
'
and in fui fo,ca and eff&d
' 15A. NAME ANO TITLE OF SIGNER (Type or punt) i 16A. NAME ANO TITLE OF CONTRACTING
Nicholas C~ung
oFfifER (Type or print)
!
202•377-3635 nicholas.chung@od gov
'
'I
;vfT/4.,,.[) Se.SJ, 15C. DATE S!GNEOI 168. UNITED STATES OF AMERICA 16C. DATE SIGNED
1SB. CONTRACTORIOFFEROR
···:... : (b)(6)
: l(b)(6)
I ;>fc,c<
')/ )011 '· MAR 06. 2012
(Signature of person authorized to sign) 1S,nnature of Contraction Cfflcer\

,, '
NSN 7~40-0 I •I _i.,-8070 STANDARD FORM 30. (Re~. 10-83)
Prcviou~ Edition unusable Prescnb~dby GSA FAR (48 CFRl 53,243
Supplementary Page
The purpose of this modification is to change the Contracting Officer from Nicholas Chung to Consuela Ginn
effective immediately.
AU other terms and conditions remain unchanged,
PAGE 2 OF 2 ED·FSA-09-D-0014/030
I AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT j' ~.e.f!Qeof PaQes
I
Coot,aollDCod•
'
1 I 13
j 2. AMENDMENT MOO/FICA TION NO. J_ EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 15.PROJECT NO. (if applicable)
' 031 MAR 05, 2012
6. ISSUEDBY CODE FSA-FS2 7 ADMINISTERED BY (If other than item 6)
United States Department of Educa1ioo CODE
Federal Student A•dlM'5sion Support Group See Block 6
630 Flrs1 SI NE - Sune 91F3
Washmglon DC 20202
Juha Jones 202-377-4263
6. NAME AND ADDRESS OF CONTRACTOR (NO., Street. Country, State and ZIP Code)
9A AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103 (x)
1200 NORTH 7TH STREET -
FINANCIAL MANAGEMENT 5TH FLOOR Cage Code 41 UK7
HARRISBURG PA 1710214-44 98. DATED {SEE ITEM 11)
i
' 10A. MODIFICATION OF CONTRACT/ORDER NO
ED--FSA-09-0-0014
I X
I CODE 0003077 4 I FACILITY CODE JUN 17, 2009
0 The above numbered solicita1ion is amended as set forth in Item 14. The hour and date specified for receipt
of offers O
is extended. Dis not exlended.
I Offers mus\ acknowledge receipl of this amendment prior to the hOur and date specified In 1he solicitation or as amended, by one of the following methods:
I {a) By completing items 8 and 15. and retummg ___ copies of amendment. (b) By acknowledging receipt of this amendment on each copy of lha offer submitted;
i Of (c) By separate letter or telegram which indudes a reference to the solicitation and ameodmenl
numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND
DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER. If by virlue of this amen\lment your desire to change an offer already submitted, sl.lChchange
may be made by telegram or letter. provided each
telenram or letter makes reference to the solicitation and this amendmenl and is received nrior to the oneninn
hour and dale S"edfiad.
12. ACCOUNTING AND APPROPRIATION DATA (II required)
Modification Amount: :i,0.00
See Schedule Modification Obligated Amount $0.00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. FTMODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER ID ISSUED PURSUANT TO· (Specify au1horily) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE AOMINISTRA TIVE CHANGES
(such as changes in paying
office. appropriation dale, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103{b)
C, THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF

X Mutual agreement between both parties
D, OTHER (Specify type of modification and au1hority)
E IMPORTANT. Contractor I
is not, Ix is required to sign this document and return
14. DESCRIPTION OF AMENDMENT/MOO!FICA '
TION (Organiied by UCF section headings, induding solicitation/contract subject matter where feasible)
E,cep( as providedtoere,n. all \ermsandcofl{!jllonsol lhe dorumenlreferenced ,n lIem9A or 10A.as heretoforechanged.

remainsunchoni;,M""<I ,n ful force andeffect
I
I
15A NAME ANO TITLE OF SIGNER (Type or print) I 1_6A.NAME ANO TITLE OF CONTRACTING OFFICER (Type or print)
I I\~
: l ) (A..1'11
I \.1,--v-,,
•
t l.A.-/ \._) '\r-----....
c-...J.)(._(' r..
~'--
N!Cholas Chung
''
II~-,-U:~iiY l CS:::
1202 377 3635 nicholas chung@ed gov
bi,£cic l~JI" ' ,; I/;( ,i,: i

15~0NTRA£FFEROR 15C DATE SIGNED~(b•/+( ,t
.,,e""u 0N0 0e0o0s0T0A0T0E0s_,o0F0 A
0M0E
0R0 ,0C0A __
,,A
6I
_., 16C. DATE SIGNED
i
I c-.-.~R 05, 2012
i1 'J,fa (L
L-..,-----,-------,-------.,,---c--,------' ,Ff< a /
I
(S1gna1ure of person authortiad lo sign) I 00 ':
NSN 75•l0-01-l52-8070 Sl Al',l)ARD FORM 30. (Rn. 10-83)
PrGv1ous t:dit,on unusable Prescnbcd by GSA FAR (-18 CFR,153.243
Supplementary Page
See Attachment A Modification Description.
PAGE 2 OF ED-FSA·09-D-OO 14/031
Supplementary Page
PAGE 3 OF ED-FSA-09-0-00 14.'031
Attachment A - Mod1f1cat1onDescription
The purposes of this modification are as follows·
1 Incorporate into the contract guidance for the Servicers on logo use and branding and provide
examples for all mailings and correspondence used in support of the U.S. D(>partment of
Education federal student loan services.
Note: Servicers are not required to use the Department of Education logo for mai!ings and
correspondence. If any of the Servicers choose to do so, guidance provided in this modification
1hall be followed.
2. If a Servicer chooses to use the Department of Education logo for mailings and correspondence,
the following conditions apply:
a. To allow for a reasonable trnnsition period and reduce the level of impact this change may
have on the parties, Servicers shall be required to provide an estimated date of transition
completion.
b. The estimated date of transition shall be provided to the Contracting Officer no later than
10 days after execution of this Modification.
c. Estimated date of transition shall require approval from the Contracting officer,
3. In accordance with Section B.13 Additional Terms and Conditions item K (Branding/Marketing
Material) of the base IOlQ,any exception or ambiguity regarding this section of the contract
shall be reported to and subsequenlly reviewed and approved by the Contracting Officer 1n
advance.
4. All other terms and conditions remain unchanged and in full force and effect.
PAGE 2 OF ED-FSA-09-D-OO
141031
Guidance for U.S. Department of Education Federal Student Loan Servicers

To help alleviate confusion among borrowers regarding the servicing of their federal student
loans, F<:'.dt:ralStudent Aid has developed a U.S. Department of Education graphical lreatment
that can be used by U.S. Department of Education servleers. U.S. Department of Edurution
servicers are those entities that the Departmcm ha.~wntracted with to service federdlly-owned
assets.
Federal Student Aid requires all U.S. Department of Education servicers to consider use of the
approved Department of Education graphical treatmem (identified below) when communicating
with U.S. Department of Education borrowers about their federally-held debt.
Approved U.S. Department of Education Graphic

Inlorn111l1011 •boul 7our led oral lftudenl loao
>!
-
Usage Guidelines
A U.S. Ocpartment of Educacion servicer, in using the approved U.S. Departmcn! of Education
graph1rnl treatment, is required to adhere to the following guidelines:
• The U.S. Depa1tmcnt of Education graphical treatment can only be used when the
servicer is communicating exclusively to U.S. Department of Education borrowers with
federally held debt
o It cannot be used in any communication pertaining tu any commercially held

~tudent loans, including, but not limited lo, Federal Family Education Loans or
private smdent loans
• The lJ.S. Department of Education graphical treatment must be used with the servicer
logo in a manner that makes it clear to the borrower that the communication is from the
servicer (not the U.S. Department of Education)
o It cannot be used on any communication material that does not also include the
servicer logo, but when used, must be separate and distinct from the servicer logo.
o It cannot be separated to the extent the U.S. Department of Education graphical

treatment and servicer logo are on different sides or pages of a communication.
• Provided the above guidelines are met, the U.S. Department of Education graphical
trcalmc:nl is appropriate for use on lhc follo>ving materiuls ( Sec attached example~)·
PAGE 3 OF EO-FSA-09-0-00141031
o Envelopes
o Paper and Electronic Correspondences
o Billing and tax statements
o Web.~ites
• When used, the U.S. Department of Education graphical trea1ment should not be smaller
than 2\1, inches wide and should not be larger than the servicer logo
Disclaimer: This U.S. Depanment ofEduca1ion graphical neatment may only be used
exclusively by U.S. Department of Education federnl student loan servicers. The U.S.
Department of Education does not authorize any other person or entity co use this graphical
treatment l\'ithout its express written pem1ission. The U.S. Department of Education seal image
on the graphical trea1ment remains the property of the U.S. Department of Education. The use of
1he U.S. Department of Education's graphical treatment does not constitute or represent an
endorsement of any products and/or services offered by the servicer.
PAGE 4 OF ED-F SA-09-D-00 141031
ACME
WUllfl'-T IDAN ~U\VlOR
1234 HIU.SID[ DR.
Los ,\NGU n Ci\ ';10011
123-555-5555
U.S. Department of Bduce.tion

lDlo"""Uoo •hon< you h><!o,ol -,odon< , ...
•
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PAGE 5 OF ED-F SA-09-0-0014/031
,\CMF
\Tl T·l>H IOM< 111,; 1,-,"
'.lJ4 H1a;,r>11)1\.. U.S. Department of Educ"llon
Lc>S A.'>(;flf> (A <,(,01 """""•Uon •boot ..,., l,dottd O<ud••• ,...,
:2,.,_<J ..\\15 •
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PAGE 6 OF ED-F SA-09·0-00 14/03 1
U.S. Department ot Education

,.,.....,,••""°"',•••,....., ......,,•••
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PAGE 7 OF E D-FSA-09-O-00141031
PAGE 8 OF ED-FSA-09-0-0014/03 1
□
ACMI
'""''N' l(};N , .. v•u•
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OC,S ANU.!S
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,,,.,,..,. ._,
PAGE 9 OF ED-FSA-09-0-00'. 41031
ACME
5TllDFNT LOArs StRVICfR
1234 Htl.LSIDE nR.
LOI ANGfl.[S CA 90()1 l
123-'.i55-S555
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PAGE 10 OF
ACME
snmFNT LO.~N)rnv1crn
1234 HlllSlDE DR
LO> -~NG[ L[5 CA '.10011
123 555-5.)55
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PAGE 11 OF ED-FSA·09-D-0014l031
1 Contract ID Code
i AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT
2. AMENDMENT MODIFICATION NO. ! 3. EFFECTIVE DATE 4, REQUISITION/PURCHASE REQ, NO I 5. PROJECT NO (rl applicable)
'
032 I MAR 15. 2012 EDOFSA-12-000250 I
6 ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If o!her !han ,tern 6) CODE
United States 0epMrnen1 of Educahon I,
Federal Sludent Aod/M,ss,onSuppor1 Grwp See Block 6 I
830 F1rs1 S! NE - Sutte 91F) I
I Wash,ngton DC 20202
I0
r,
1
-,-' 09A~A"M=E'N"O"M"E"N"T~O"F'S"O"L'IC=1T"A'T"IO"N=N"O'.--
8'.'N"A"M"E""A'N"D"'A"D"O"R"E''S"S'O"°F'C"O"N"T"R"A"C"T"O"R"'(N""O','S""'e'e'l,'C"o'o•o'l~','S'la"l'o'a'od,l,Z",C=C•od"e")---~-
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS 007366103 !--- 11
1200 NORTH 7TH STREET Cage Code: 41UK7

EO-FSA-'J'i-0.00H
X
D The above numbered sol1c1ta11on 1samended as set forth in item 14. The hour and date specified for recelp1 of offers D ls extended. Dis not eX1ended
Offers must acknowledge receipt of this amendment prior to !he hour and date specified in the solicitation or as amended. by one ol 1he following methods.
(a) By completing items 8 and 15. end returning ___ copies of amendment: {b) By ecknow!edgmg receipt of this amendmen! on each copy of the offer submil1ed;
or (c) By separate lelter or telegram which includes a reference to the sol1c,ta11on
and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
1
YOUR OFFER If by virtue of this emenctment your desire to change an offer already submitted. such change may be made by telegram or letter. prov,ded each
telegram or letter makes reference lo the solic,tat,on and this amendment, aml is rece,ved n11orto the onernnn hour and date snecified
12 ACCOUNTING ANO APPROPRIATION DATA (lf required) Mod1ficat1on Amount· $19,000.000 001
See Schedule Modification Obligated Amount $19.000,000.00,
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTSJORDERS, IT MOOIFlES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER 10 ISSUED PURSUANT TO (Specify au1hority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
8 THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes ,n paying
office, appropnaUon date. elc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b)

X Mutual Agreement Between the Parties
D. OTHER (Specify lype of rnodificat1on and authority}
E IMPORTANT: Contractor I 1s not, Ix 1s required to sign this do.0c0,,,m

0 e0o010a0o0dc_cce,l,o"m'-"'~""'
7
,l,ol
c~cPci"e"s 0s0o0m0g,.cocffic"'"-'-~".. -----I
,0he'-'is
14 DESCRIPTION OF AMENDMENT/MODIFICATION {Organized by UCF section headings, including sohci1allon/contract subJect matter where feasible)
Ewepl as prm,1ded herein, all terms and con~rtions ol lhe docurMnl referenced ;., ~em 9A o, I OA_a, r.e,ctoJore ct,ange<I. rem,,;ns unct,anqc<j arld in rull force ond ctt<>CI
I 15A NAME ANO TITLE OF SIGNER (Type or pnnt) • 16A. NAME ANO TITLE OF CONTRACTING OFFICER \Type or pnnt)
i
'ffi~10C)~ 1
,Consuela Ginn, Contracting Officer
202-377-3589 Consuela G1nn@ed.gov
•W-rN~Y\
~NTRAC
' ---~c:_------~-
(b)(6)
_OITTRQ~.- ISC
b)(6)
8 UNITED STA TES OF AMERICA JJ' !6C DATE SIGNED
MAR 15, 2012
(Signature of person authoriled to sign) 7i,-o"m~~-,~-

L-,s~·-,"a"""~1"c",-,",,-,-ci
NSN 75W"Ol-152-8070 STANDARD J<'ORMJO. (Rn. I0--83)
Previous [di1ion umtS3ble Pre,,<:ribcJ b} GSA FAR (--18CFR) 53 243
Supplementary Page
The purpose of Modification 032 to ED-FSA-09-D-0014 is to provide funding for

servicing operations.
The total contract value is increased by $19,000,000.00, from $129,019,578.1 0

to $148,019,578.10.
PAGE 2 OF 3 EO-FSA-09-O·00141032
(New Line llern)

0019 Pennsylvania Higher Education Assistance Agency to 1 00 SE 19,000,000.00 19,000,000 00
provide serviang operations for FSA
'1
L__
--- --------- ...- ---- . ___
i _____ -'--- ----- .,,_,. _______ (, -------- ___J
PAGE 3 OF 3 ED-FSA-09-0·0014,'032
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT : 1

Coalcac"OCode ~a_ge_ -·- _i
~f ;a_g_~s
:z.
'
AMENDMENT MODIFICATION NO 3. EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO
1
5. PROJECT NO (it applicable)
3
! 033 MAR 15. 2012 EDOFSA-12-000251
: 6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other 1han nem 6)
Un,ted Stales Depanment of EdLJCa~on CODE
I Federal SI\IOenl A1,:I/M,ss,onSupport Gmup See Block 6
, 630 First St NE· $u~e 9IF3
i Wash1ngtoo DC 20202
I
i
I 8. NAME ANO ADDRESS OF CONTRACTOR (NO, Street. Cour1try. State af\d ZIP Code)
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA DUNS 007368103
I I>)
9A AMENDMENT OF SOLJCITATION NO ~
'
f------
I HARRISBURG PA 171021444
Cage Code· 41UK7
i
' I
I 10A. MODIFICATION OF CONTRACT/ORDER NO
EllhA-tl9-D-O!J14 '
' X
108, DATED (SEE ITEM 13)
'I
I
I
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICtTA TIONS
D
The above numbered sohc1tat1onrs amended as set forth in item 14 The hour and date specified for receipt ot
offers D
Is extended. 01s not extended. I
Offers mus1 acknowledge receipt of this amendmen1 prior to the hour and dale specified in the sohci!at1on or
as amended, by one of 1he following methods·
(a) BY completing items 8 and 15, and returning __ ~ copies of amendment. (b) By acknowledging rece1p1of this amendment on each copy of lhe offer submitted: i
or (c) By separate letter or !clegram which includes a reference to the solIatat1on and amendment numbera.
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR ANO
DATE SPECIFIED MAY RESUL f IN REJECTION OF
'
I
YOUR OFFER If by virtue of \hrs amendment your desire to change an offer already submitted. such change
may be made by telegram or letter, provided each !
_teleg!_am01 letter makes rele~-~-~o 1he_ __
solici.ta11onand this amendment. and is received .e.rior IQ.~p~ning '
tIour and 2ate specified.
1 12 ACCOUNTING AND APPROPRIATION DAT A (II required)
' See Sc he d ueI

Mod1ficat1on Amount
ModIfIcation
$500,000 ool
Obligated Amount $500 000 00
!
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED
IN ITEM 14.
Check One A THIS ORDER ID ISSUED PURSUANT TO (Specify authorily) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES

\such as changes in paying
office, appropriation dale. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b)
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

' X Mutual Agreement Between the Parties
0. OTHER (Specify type of modification and authority)
'E IMPORTANT Contractor I Is not, D<is required to sign this document and re(urn 1 copies lo the issuing office
14 DESCRIPTION OF AMENDMENT/MODIFICATION {Organized by UCF section headings, including SOhClta1ionlconlract subJect matter where feasible)
, Excep! as pro111dedhero,n. all terms and cond11;ons ollhedoCtJmenl ceforencod 1n«en 9A or IOA. •• l>erelofo,e ch•nlJl)O, rema>ns unchangad and•~ full f.wu ""~ etleci
15A. NAME AND TITLE OF~GN_ER (Type or print)
!
D 16A NAME ANO TITLE OF CONTRACTING Ofl'ICER
ii
(Type or pnnt)
f'v\,-, ~ I~. •1 'Consuela G;nn. Con1racting Officer
L,tTIJ c,.\10
iI \ • , 1202-377•3589 Consuela Ginn@ed gov
' \IP-rTox.u,VV\",11Pct:c;\£cilfl;\)"' c::.,n
1,,.~~
1:f;iigQN~'½BQ7'" I '.--r5C~E~,TE"O_"s_"T'A"T_"ES=()"F'.A'M"F'R"!C"A~_-_- __~i~'"6C'M~:':T1f5S::::D
I (° ..... #.,,.-Z 7
i '
(Signature of pe,son authorized to sign)
na of Contractin Officer
!\SN 7540-01- I 52-8070
ST,\~DARD FOHM 30. (Rev. 16-83)
Pre\ ious /'dilion 11m1>,1bk
Prescribed t,y GSA Fr\R 1 18 tTR) 5] ~~3
Supplementary Page
The purpose of Modification 033 to ED-FSA-09-O-0014 is to provide funding

for system changes and
enhancements.
The total contract value is increased by $500,000, from $148,019,578.10

to $148,519,578.10.
AU other terms and conditions remain unchanged.
PAGE 2 OF 3 EO-FSA-00-0-00141033
1CostApphed: $500,000.00
I_
,(New Line Item) ,

0020 IPennsylvania Higher Education Assistance Agency to 1 00 I SE 500.000 00
I make enhancements and system changes requested by 1 500,000.00
FSA I
'
I
-~-J
PAGE 3 OF 3 ED-FSA-09-0-00141033
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT j 1 Contract ID Code I Paue of Pa<1es
13. I 1 I 4
2. AMENDMENT MODIFICATION NO EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 15. PROJECT NO (if applicable}
0034 MAR 15. 2012
6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (/f other than item 6)
UMed States Departmeol of Educa11on CODE
Federal Student Aid/Mission Suppo,t Group See Block 6
830 F,rs1 St NE. Suite 91F3
Wash.,gton DC 20202
8. NAME ANO ADDRESS OF CONTRACTOR (NO., Streel, Country, Stale and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103 (X)
~
Cage Code. 41UK7
HARRISBURG PA 171021444 9B. OATED(SEE ITEM 11)

ED-FSA.W.D-0014
X
D The above numbered solici1atlon is amended as set forth m item 14. The llour and date specified for receipt of offers Dis extended, Dis no1 e~tended.
Offers musl acknowledge receipt of this amendment prior to the hour and dale specined In the solicitallon or as amended, by one of the following methods:
(a) By complellng Items 8 and 15, and returning ___ copies of amendment; (b) By acknowledging receip! of this amendment on each copy of the offer submitted;
or (c) By separale letter or telegram which incll.Jdes a reference lo the solicitation and amendmeot numbers. FAILURE OF YOUR ACKNO\NLEDGMENT TO BE
YOUR OFFER. II by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each
telenram or letter makes reference to the sol1citatioo and this amendment. and 1sreceived pnor to the oneninn hour and dale SnAcifled.
12. ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: $0.00
See Schedule Modification Obligated Amount: $0 00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED tN ITEM 14.
Ch-eek One A. THIS ORDER 10 ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (sud1 as changes in paying
office, appropriation date, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103{b).

0. OTHER (Specify type of modification and auttiority)
E. IMPORTANT: Contractor I 1s not, fx 1s required to sign this document and return copies to the issuing office.
'
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicltalionlcontract subject matter where feasible)

;
'!
"1!erenced In rtem SA or 1011.ss MreloJore chMgod_ remains unchanged ood in full forw ond effeel
Elo::epl as pro""'ed he"1in, all lerms and conaillons of lh<I OOCI.IITlffi1
15A NAME AND TITLE OF SIGNER (Type or print) 16A NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
b SB:c"-
:\1w\-11:?vv Consuela Ginn, Conlracti"8 Officer
202·377-3589 Consuela lnn@ed.gov
(/? + Pn)c""·""'l\ · ' ,,

158. CONTRAC /OFFER 15C. DATE SIGNED 16B. UNITED STATES OF AMERICA 16C DATE SIGNED
(b)(6)
'
I, b)(6)
{Signature of person authorized to sign)

'!/;/~ I Ila ur 0 onrracimo
~·
APR 10, 2012
NSN 7540-01-152-8070 STANDARD FORM: 30. (Rev. 10-83)

Previous Edition wrnsablc Prescribed by GSA FAR (48 CFR) 53.243
Supplementary Page
The purpose of Modification 0034 to Contract# ED-FSA-09-O-0014 is to definitize the Change Request (CR)
Threshold for low-effort changes. See Enclosure 1.
PAGE 2 OF+ ED·FSA-09-D-0014/0034
Supplementary Page
PAGE 3 OF if, ED-FSA-09-D-0014/0034
Enclosure 1
Change Request BIiiing Thresholds
Threshold Per Effort Thrvshold Per Year Number of Changn Contract Year
Per Year Anniversary
$2,500 $25,000 N/A October 1
Appllcallon of Thrvsholds:
1. FSA will not be b~led for Change Requests (CRs) having a lotal biNable
value of less than the
Threshold Per Effor1 (Low Effort CRs) until lhe aggregate billable value
of all such Low Effort CRs
e><:ceedsthe Threshold Per Year for !he current Contract Year.
2. FSA Will be btlled for each Low Effort CR requested beginning with the
Low Value CR thal results
in the aggregate bilflng value of all Low Value CRs exceeding the Threshold
Per Year for the
current Contract Year.
3. Each CR haVlng a bilable value in eKcess of the Threshold Per Effort

shalt be biQedto FSA
without consideration of the Threshold Per Year. The Threshold Per Year
applies only to Low
Value CRs.
4. Calculation of the aggregate billable value of Low Value CRs willbegin on

lhe Contract Year
Anniversary for eacti Contract Year.
Examples:
1. One CR is requested by FSA dunng the Contract yt-ar. having a billable value
of $10.000.
Amount bllled to FSA: $10,000
2. Twelve CRs are reques!ed by FSA during the Contract Year: each
has a blllable value of $2.400.
Amount billed to FSA. i4.800 (lirst 10 Low Value CRs have $24,000
aggregale value and are
no1 billed: Threshold Per Year Is met and exceeded for the last two billed
CRs)
3. Three CRs requested by FSA CR1 - $24,000. CR2 - $2.000; CR3 - $2.000
Amount bl/led to FSA: ($24,000: CR2 & CR 3 are not billed because the
annual threshold for
Low Value CRs has not been reached.
PAGE'rOFI-/- ED-FSA-09-D-0014/0034

1 ·ContractlDCode I Pa~eofrag;s ___
2. AMENDMENT MODIFICATION NO. 13.EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 15.PROJECT NO. (11applicable)
0035 MAR 16. 2012
6 ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE
Un•1ed State,, Depanmen1 of Educauon
I Federal Student AKilM,ssron Support Group

830 Firs\ St NE - Suite 91F3
See Block 6
I Washingion DC 20202
8. NAME AND ADDRESS OF CONTRACTOR (NO .. Street Country. State and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA OUNS: 007368103
1200 NORTH 7TH STREET Cage Code· 41UK7

ED.fSA-09-D-001 ◄
X
1DB DATED (SEE ITEM 13)
D The above numbered solicitation is amended es set forth in item 14. The hour end date specified for receipt of offers Is extended, Dis O
not exlended.
Offer, mus I acknowledge receipt of this amendment prior to 1he hour and date specified in !he solicitation or as amended, by one of the following methods:
(a} By completing items 8 and 15, and returning ___ copies of amendment, {b) By acknowledging receip1 of this amendment on each copy of the offer submitted;
or {c} By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted. such change may be made by telegram or letter. provided each
teleoram or letter makes reference to lhe solic1ta1,onand this amendment. and ls received nrior lo the oneninn hour and date s=cified.
12 ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount· $0.00
See Schedule Modif1c.ation Obligated Amount: $0.00
Check One A THIS ORDER ID ISSUED PURSUANT TO. (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes In paying
office, appropr1at1ondate. etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF.

D OTHER (Specify type of modification and authority}
E. IMPORTANT: Contractor I is not, Ix is required to sign this document and return 1 copies to the Issumg office.
14 DESCRIPT!ON OF AMENDMENTIMODIFICA TION (Organ,ied by UCF section headings. including sol1citation/contract subJec1matter where feasible)
faC"!]t as provided herein, ,.11terms and coodit,o.-.s of lhe documenl referor>ee<Ih1,(em 9A Of •OA. as t>erelofon: ctianged, ramart1s t.01chan~od ~nd In lull km;e and effed.
NSN 7540-01-152-8070 STA;>,;OARJ)FOR~t JO. (Rev. 10-83)

Pre\ious Edition unusable Prescribed by GSA FAR (-18CFR) 51243
Supplementary Page
The purpose of Modification 0035 to ED-FSA-09-O-0014 is to incorporate part two of the guidance regarding
the Direct Loan Consolidation Incentive Plan.
PAGE 2 OF t; ED-FSA-09-D-0014/0035
Supplementary Page
PAGE30Ft
Special Direct Consolidation loan Program - Incentive Plan Part II

INCENTIVEPLANSUMMARY
This i11cent1veplan will reward the TIVASwith traditlonal loan consolidation loan volume for one year
based on demonstrated success of their campaign for the Special Direct Consolidation Loan opportunity.
GOALOF THE INCENTIVEPLAN;

Create incentives to encourage the TIVASto effectively reach out to eligible borrowers to
consolidate under this opportunity.
Create incentives to encourage the TIVASto consolidate the loans indicated on the applications in a
timely and effective manner
INCENTIVEREWARD
Traditional consolidation loans booked on or after August l, 2012 and before August 1, 2013, will be
distributed to the top two performers of the SOCLopportunity for one year based on the details below
This volume could be around 600,000 borrowers (number Is based on the historic data for the number
of consolidations in prior years).
DETAILS
Proces5:
The metric will be calculated on Jyly 15, 2012based the number of submitted applications and
successfully booked consolidation loans There will be two metrics (see below).
The incentive award borrowers will begin to be distributed August 1, 2012.
The top performer based on the metrics below will receive 60% of the traditional loan consolidation
volume for one year; the runner up performer will receive 40% of the traditional loan consolidation
volume for one year; the two lowest performing will receive no award borrowers.
Performance Metrics Calculatlon:

• Metric 1: Number of applications as a percentage of the total number of eligible applicants.
This metric will be weighted 50%.
• Metric 2: Number of booked loans as a percentage of the total number of eligible loans that
could have been booked from the application. The source of this metric calculation will be
NSLDS. This metric will be weighted 40%.
·1·otalNumbcror ApplicatimsSubmittedSincc Inception x 0. x
6 100
Total No.of Eligible Applicants
PAGE r10Fb ED-FSA·09-0-001410035
Metric2 Cakula\Jon:
TntalNo.ofSOCL loansBonked
X 0.4xl00
Total No. of FJigible and !ndicatcdas 'CDnsolidat' 011 theSubmittedApplicatims
Metric 1 + Metric 2 =%to normalize to de term me% of incentive allocation
Example;
TIVASl had 100 total elieible borrowers to reach out to of which 40 submitted promissory notes.
Contained in the submitted application were 300 loans in the "I Want to Consolidate" section. Only 200
of those loans were eligible loans for comolidation TIVAS1booked a total of 100 loans.

40/100=0.4 X .6 =0.24
100/200=0.5 X 0.4 = 0.2
0.24 + 0.2 = 0.44d00 = 44%
TIVAS2had 200 total eligible borrowers to reach out to of which 150 submitted promissory note~.
Contained in the submitted application were 600 loans in the "I Want to Consolidate" section. Only 500
of those loans were eligible loans for conrnlidation. TIVAS2booked a total of 400 loans (a lew
borrowers submit the 'Request to Add loans' form alter wbmitting the application. From these forms,
the TIVASbook 20 loans which are included in the 400 booked loans total.)
150/ 200:0 75,0.6=0 45

400/500=0 Bx0.4=0.32
0.45+0.32=0.77Xl00:77%
TIVAS3had 100 total eligible borrowers to reach out to of which 50 submitted promissory notes.
Contained in the submitted appl,cat,on were 350 loans in the "I Want to Consolidate" section. Only 250
of those loans were eligible loans for consolidation.
TIVA53booked a total of SO loans.
Performance metr;c calculations for TIVASl:

50/100:0.5 X .6 "0.30
50/250=0.2 X 0.4" 0.08
0.30 + 0.08 = 0.38Xl00"' 38%
PAGE 3 OF EO-FSA-09-0-0014i0035
TIVA54had 250 total eligible borrowers to reach out to of which 150 submitted promi>sory notes.
Contained in the submitted application were 650 loans In the "I Want to Conrnlidate" section. Only 500
of those loans were eligible loans for consolidation. TIVA51booked a total of 250 loans.

150/250=0.6 X .6 = 0.36
250/500=0.5 X 0.4 = 0.2
0.36 + 0.2 = O.S6Kl00 = 56%
Normallzatlon Calculatlons;
44% + 77% + 38% + 56% = 215%
Since 215%does not equal 100%, the metric needs to be normalized,
Normalize to 100 % to determine the percentage of the total incentive allocation b'/ dividing by 215,
100/215 = 0.465
215*0.465" 100 %
Mult,ply each performance metric by O 465

TIVASt - Performance metric= 44*0.465= 20.5%
TIVAS2- Performance metnc "77'0.465= 35.8%
TIVA53- Performance metric= 38'0.465= 17.7%
TIVAS4 Performance metric= S6•0.46S- 26.0%
Sum: 100.0%
TIVAS2and TIVA54were the top performers:

TIVA.52will receive 60% of the tradltlonal loan comolldat!on volume for August 1, 2012 to July 30,
2013.
TIVA.54wlll receive 40% of the trndltlonal loan consolidation volume for August 1, 2012 to July 30,
·12013.
TIVA.51and TIVA.53 will not receive any award borrower volume.
PAGE 4 OF EO·FSA-09-0·001410035
' 1 Con1ract 10 Code , Paue of Paaes

i
! 2 AMENDMENT MODIFICATION NO 13EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO
' 1
PROJECT NO {•f applicable)
I 5
'
I 0036 APR 23, 2012 I'
6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than rtern 6) CODE
Umted S1ales Departmen1 of Educa!Jon
Federal S!u<!en1 Aod/M,ss,on Support Group See Block 6
830 First S1 NE· Su,te 91FJ
Washmglon DC 20202
'
8. NAME ANO ADDRESS OF CONTRACTOR {NO., St1eet. Country, State and ZIP Code} 9A. AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA DUNS· 007368103 (,)
1200 NORTH 7TH STREET 1--
Cage Code: 41 UK?

EO-FSMr9-D-0014
X
0 The above numbered solicltallon is amended as set for1h in I1ern 14. The hour and date specified for receipt of offers D Is extended. Dis not extended.
Offers mus1 acknowledge receipt of lhts amendmen1 prior to !he hour and dale specified ,n !he solicitation or as amended. by one of the following methods:
(a} By completing items 8 and 15, end returning ___ copies of amendment. (b) By acknowledging receipt of this amendment on each copy of 111eoffer submitted,
or (c) By separate letter or telegram which includes a reference to the solicdat1on and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letler, provided each
teteQrarn or letter makes reference to the sohc1talion and 1his amel'ldment, and is receivet!.£_rior lo the ooernno hour and dale specified.
12. ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount. >1>0.0
See Schedule Mod1f1cation Obligated Amount. $0.00
Check One A. THIS ORDER 10 ISSUED PURSUANT TO: (Specify au\hori1y) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B THE ABOVE NUMBERED CONTRACT/ORDER tS M001FIEO TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in payil'lg
office, appropriation dale, elc} SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b)

X Mutual Agreement by Both Part1es
D OTHER (Specify type of modification aod authority)
E. IMPORTANT Contractor I Is not, IX Is required 1o sign this document and return

14. DESCRIPTION OF AMENDMENT/MODIFICATION ' copies to the IssuIng office.
(Organized by UCF section headings, 1nduding soliatationlcon!ract subject mailer where feasible)
hcop( ao pro,..dcd horoln. a! (erms and wOOttQns of (he docum<ml rafe.-anmd in •t<>m
9A or 10A. as Mratotora ch"'1gad, remains uocNln ad ond ,n full force and eN&Cl
I
. 15A. NAME AND TITLE OF S~NER (Type or pril'lt) , 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or pnnt)
"'-->D
! 1\):c-\-1-ne ,:£':;::{>, i Consuela Ginn. Contracl1ng Officer
!202.377.3539 Consuela Gonn@ed gov
\\:> ~ Rcc,c<-1AU,ilQ¾,:irtr1
l.aJ1 Sirv;1
158. CONTRACTOl'll FEROR 1 15C. DATE SIGNE ,...B, UNIT\:D STATES OF AMERICA 16C DATE SIGNED
b)(6)
I Jb\(6\
I (Signature of pe1s0t1 authorized to sign)

na ure o onuarnnu
NSN 7540-01- 1.'i2-&070 SIA~DAHD FORl\1 JO. (Rev. 10-83)
Prcviu11s FU,11on unusable Prcmibed by GSA FAR (48 CFR} 51.243
Supplementary Page
The purpose of Modification 0036 to Contract #ED-FSA-09-D-0014 is to replace Section B.11 FSA 32-1
Invoice Procedures (August 2007) with FSA 32-1 Invoice Clause (MAR 2012).
See Enclosure 1 for the full text of the revised clause.
PAGE 2 OF ED·F SA..QQ.o.oo1410036
-·-- ----·
SCHEDULE Continued
- -
lfEr,I NO. SUPPLIES/SERVICES OUANflTY l UNIT UNIT PRICE $ AMOUtfl $
Cont racling Officer: Consuela Ginn, 202-377 -3589.

Coosuela.Glnn@ed.gov
Cont racting Officer Representative. Tammy Connelly,

202. 377.3298, tammy.connelly@ed.gov
Tech nical Point of Contact
I
I' I
I
PAGE 3 OF E D-FSA-09-D-00 1410036
ENCLOSURE 1
FSA 32-1 Invoice Clause (MAR 2012)
The Contractor must submit an invoice via mail, fax, or e-mail for this contract in
order to be paid for products and/or services rendered. For Prompt Payment
Act purposes, Invoices received after 3 p.m. will be processed on the next
business day.
Federal Student Aid's "Designated Billing Office" {DBO) is:
Union Center Plaza
Federal Student Aid Administration
830 First Street. NE - Suite 54B1
Washington, D.C. 20201-0001
E-mail: lnvoiceAdmin@ed.gov
Fax: (202) 275-3477
A contractor shall also simultaneously submit copies of the invoice to the

Contracting Officer (CO) and one to the Contracting Officer's Representative
(COR). The CO and COR should receive copies via the same means as the
invoice sent to the DBO.
When submitting an invoice via mail, the Contractor shall submit the original
mvoice and two copies of the invoice.
At a minimum the following items must be addressed in order for the invoice to
be considered "proper" for payment:
(1) Name and Address of the Contractor.

(2) Invoice Number and Invoice Date.
(3) The Contract number, contract line item, and if applicable, the order number.
(4) Description, quantity, unit of measure, uni( price, and extended price of
the delivered item or service, as defined in the contract or order.
(5) Terms of any offered prompt payment discount.
(6) Name, title, and phone number of persons to be notified in event of a
defective invoice.
(7) The period of time covered by the invoice.
(8) Totals, supported by subtotals, and subtotals should be supported by detail
(i.e. documentation for categories of labor, hours performed, unit prices) and
deliverables provided.
(9) Jf required by this contract or order, receipts must be provided to support
documentation of •·other direct costs" (OOCs) or materials.
PAGE 4 OF EO-FSA-09-D-001410036
(10) SPECIAL INSTRUCTIONS FOR FINANCE PAYMENTS:

Invoices for finance payments shall specifically and prominently identify the
payment request as follows:
REQUEST FOR FINANCING PAYMENT
Finance payments are not subject to the Prompt Payment Act Failure to identify
the invoice as a request for financing may result in delay of payment. Invoices
that are identified as Requests for Finance Payments shall only include the
finance payments listed in the contract. Requests for finance payments shall not
be combined with other types of invoice payments.
PAGE 5 OF ED-FSA-09·0-00 1410036
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT I I

Cootmci ID c""'
IPaaeof~
I 1 I 7
2. AMENDMENT MODIFICATION NO. 13.EFFECTIVEDATE "· REQUISITION/PURCHASE
REO. NO. 15. PROJECT NO (ii applicable)
0037 APR 27, 2012
6. ISSUED BY
United Stein Departm"'11 of Ed~calion
CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE
Federal St...:leflt Ad/Mi<$l<>n Supp,oo1Group See Block 6
a,o Fint St NE · Suite 91F3
'Ml$hmgton DC 20202
Soo Kall; 202-377-3798
8 NAME AND ADDRESS OF CONTRACTOR (NO., Street. Coonl,y, State and ZIP Code) 9A AMENDMENT OF SOUCITAT10N NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS. 007368103 1,1
~
10A. MODIFICATION OF CONTRACT/ORDER NO

EO.fSA-09-IHKJU
X
108. DATED(SEE ITEM 13)
CODE 00030774 I FACILITY CODE JUN 17. 2009
0 The above numbered solicitation is amended as set IO!th in i!em 14. The hour end dale specified for receipt of offers Is eKteflded, l'\01e:<teflded. D Dis
Offers must acllnowledge receipt of this amendment priOf lo tile hour and date specified In tile sollcltallon Of as amended, by one of the fotlowing rnelhods:
(a) By completing items 6 and 15, and returning~~ copies of amendment; (b) By aclmowledging receipt of 1his amendment on each copy of lhe offer submitled;
Of (C) By separate letter or telegram which includes a relerence to the sotlcilauon and amendment numbers.FAILURE OF '!'OUR ACKNOW\.EDGMENT TO BE
RECEIVED AT THE PlACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION Of
YOUR OFFER. If by virtue of this amendment your desire lo change an offer already submitted, such change may be made by te~ram or letter. provided each
lel=rnm or letter makes fefefence to the sohcilatlon and this amendment and 1sreceived nrior to the o "'"" hour and dale s=dne<1.
12. ACCOUNTING ANO APPROPRIATION OAT A (If required) Modi..-lion Amount: .,., 00
See Schedule
Modification Obligated Amount: $0 00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF C0NTRACT$10RDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A THIS ORDER 10 ISSUED PURSUANT TO· (Specify aU1hority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
8 THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as chal)(JeS In paying
office, approprlalion da!e, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103\b)
C. THIS SUPPLEMENT AL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF

X Mutual Agreement between Both Parties
D. OTHER (Specify fype of mod,flcalionand aulhorify)
E. IMPORTANT: I Ix is required to the issuing office.

Contractor
14. DESCRIPTION OF AMENDMENT/MODIFICATION
is not. to sign this document and return
' copies
(Organized by UCF section headings, Including sollcitaHonlcootract ,ubject matter where feasible)
I
~>o:oopt a, pro.,dod llero,n, an term• and c.ondilO<l• of lhe ~ocumenl ,el.,.,ocedln olem11Aoc IOA,.,. h0<elol0<& ch0<1~. ,.,..,,..,. und'I., arid ;,, Mt for~ - el!oct.
16A NAME AND TITLE OF CONTRACTING OFFICER (Type Of print)
~ITLE't:5~rint)
I U Consuela Ginn. Contractin3 Officer
202-377•35fl9 Consuela. lnn@ed.gov
I '
I\
D.·"'
-r·
ll'Y1I'·
i'.llf' II
, .en.... I/ "lr,~f\ \i(i /1
1 B. CONTRA UNITED STATES OF AMERICA 16C. DATE SIGNED
'
1/27
RJOFFER 15C. '-'"'<= SIGNED
b)(6)
I tfy 71 JO/l '
i
b)(6)
Af.. 2012
I
!
(Slgna1ure of person authoozed to sign) !' i

' ' e of Co-ntfacti Offioer
NSN ?540-01• I )2-80 .,0
. STANDARD FORM JO. (Rev. 10-83)
Previou~ Edition unusable Prescrit>edby GSA FAR (48 CFR) 53 243
Supplementary Page
The purpose of Modification 0037 to Contract #ED·FSA-09·0-0014 is to distribute additional 488 Personal
Identity Verification (PIV) tokens to the Contractor. Tokens are being issued as Government Furnished
Property (GFP) in accordance with the Terms and Conditions of the Contract The serial numbers of
tokens being distributed to the Contractor are listed in Attachment 1 to Enclosure 1.
PAGE 2 OF 1 ED·FSA-09-0-001410037
--
SCHEDULE Continued
ITEt/lNO. su,,ue,istRvteu QUANTITY UNIT UMTl'RlCE I AMOU~ I
Contracting Officer: Consuela Ginn, 202-377-3589,

Consuela.Ginn@ed gov
Contracting Officer Representative: Tammy Connelly,

202.377.3298, tammy.connelly@ed.gov
Technical Point of Contact:
'
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PAGElOF7 EO-FSA-09-0-01)14/0037
Enclosure 1
Date: 4/27/2012
Contractor Government Property Manager: Ann Kimmel
FSA Contracting Officer: Consuela Ginn
Contract Number: ED·FSA-09-D-0014
Subject: Government Furnished Property (GFP)
The VeriSign& ID Protection Personal Identity Verification (PIV) tokens are being issued to the property
manager for assignment to all personnel who support the above-mentioned contract. See Attachment 1
for serial numbers of the tokens being issued to the contractor.
Contractor Government Property Manager's Signature:
Jb)(6)
TFA User Handout Provided:

b)(6)
Page 4 of7
Serial Numbers of Tokens Issued to PHEAA

AVT849701203 PHEAA AVT849701471 PHEAA AVT849701932 PHEAA AVT849702398 PHEAA
AVT849701174 PHEAA AVT849701S19 PHEAA AVT849701965 PHEAA AVT849702S92 PHEAA
AVT8497011S8 PHEAA AVT849701502 PHEAA AVT849701973 PHEAA AVT849702584 PHEAA
AVT84970137S PHEAA AVT849701713 PHEAA AVT849702058 PHEAA AVT849702621 PHEAA
AVT849701367 PHEAA AVT84970170S PHEAA AVT849702040 PHEAA AVT849702630 PHEAA
AVT849701318 PHEAA AVT8497016S0 PHEAA AVT849702226 PHEAA AVT849702689 PHEAA
AVT84970129S PHEAA AVT849701633 PHEAA AVT849702242 PHEAA AVT849702701 PHEAA
AVT849701211 PHEAA AVT849701869 PHEAA AVT849702322 PHEAA AVT84970278S PHEAA
Page5of7

AVT849702873 PHEAA AVT84982841S PHEAA AVT849828886 PHEAA AVT849827891 PHEAA
AVT849828021 PHEAA AVT849828499 PHEAA AVT849828968 PHEAA AVT849827S88 PHEAA
AVT8498280S6 PHEAA AVT849828520 PHEAA AVT849828992 PHEAA AVT849827S53 PHEAA
AVT849828097 PHEAA AVT849828S62 PHEAA AVT84982703S PHEAA AVT849827S12 PHEAA
AVT849828101 PHEAA AVT849828S79 PHEAA AVT849827043 PHEAA AVT849827S04 PHEAA
AVT849828144 PHEAA AVT849828802 PHEAA AVT849827086 PHEAA AVT84982746S PHEAA
Page 6 of 7
AVT849827738 PHEAA AVT849185024 PHEAA AVT849185768 PHEAA

AVT849827746 PHEAA AVT849185016 PHEAA AVT849653386 PHEAA -
-
~

AVT849827787 PHEAA AVT849185240 PHEAA AVT849653020 PHEAA -
------
AVT849827795 PHEAA AVT849185258 PHEAA AVT849653038 PHEAA ------
AVT849827230 PHEAA AVT849185274 PHEAA AVT849653054 PHEAA --
------
AVT849827980 PHEAA AVT84918S303 PHEAA AVT849653087 PHEAA --
------
AVT849827971 PHEAA AVT84918S311 PHEAA AVT849653095 PHEAA
AVT849827369 PHEAA AVT849185338 PHEAA AVT849653118 PHEAA --
------
--
------

AVT849827264 PHEAA AVT849185395 PHEAA AVT8496S3175 PHEAA -
------
~

AVT849827377 PHEAA AVT8<!19185598PHEAA AVT849653206 PHEAA
---
--
AVT849827947 PHEAA AVT849185580 PHEAA last Item Nothing Follows
AVT849827301 PHEAA AVT849185571 PHEAA ~ ---
~
AVT849827310 PHEAA AVT849185563 PHEAA

AVT849827328 PHEAA AVT8491855SS PHEAA ---- --
------
AVT849185196 PHEAA AVT849185539 PHEAA ---
---
---
AVT849185170 PHEAA AVT84918SS14 PHEAA ------ -
----
AVT849185161 PHEAA AVT849185506 PHEAA ------ ------
----
~ ~

AVT84918S145 PHEAA AVT849185483 PHEAA ---
------
-
----
--
------
AVT849185104 PHEAA AVT849185442 PHEAA ------
~
AVT849185090 PHEAA AVT849185434 PHEAA ~ ------

AVT849185081 PHEAA AVT849185426 PHEAA ----
------ ------
AVT849185073 PHEAA AVT84918S418 PHEAA
AVT849185065 PHEAA AVT849185805 PHEAA ----
---- ---
--
~
AVT84918S0S7 PHEAA AVT84918S792 PHEAA ~

------
Page 7 of7
---- ---
1 Contract ID Code
i
2. AMENDMENT MODIFICATION NO 3 EFFECTIVE DA TE 4, REQUISITION/PURCHASE REQ NO, 15,PROJECT NO (1! applicable)
I
0038 1 JUL 12. 2012 EDOFSA-12-000536
6 ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If o!her than item 6) CODE
United States Department of Educat,on
Federal Student A1d/M1ss,on Support Group See Block 6
830 F,rst S1 NE • Suote 91 F3
Wastlmgton DC 20202
8. NAME AND ADDRESS OF CONTRACTOR (NO .. $(reel. Country. Stale and ZIP Code) 9A AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA OUNS 007368103
1200 NORTH 7TH STREET Cage Code: 41UK7
HARRISBURG PA 171021444 98 DA TED (SEE ITEM 11)

EO-rSfl-09-D-0014
X
CODE 0003077 4 I FACILITY CODE JUN 17. 2009
D The above numbered sohc1tation is amended as se1 forth in item 14. The hour and dale specified for receipl of offers D is extended, Dis not ex1ended.
Offers must acknowledge receipt of this amendment prior to the hour and dale specified in the solicitation or as amended, by one of the following methods: 'I
{a} By completing ii ems 8 and 15. and returning __ copies of amendment. (b) By acknowledging receipt of this amendment on each copy of the offer submitted:
or {c) By separale letter or telegram which includes a reference !o the solicitation and amendment numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE
YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted. such change may be made by telegram or letter, provided each
i
telenram or letter makes reference to the sohc1tallon and this amendment, and 1sreceived nrior to the onenmn hour and date snecified.
12 ACCOUNTING AND APPROPRIATION DAT A {If [€Quired) Modification Amount: $71. 780 00 I
See Schedule Modification Obligated Amount $71,780.00I
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14. :
Check One A THIS ORDER ID ISSUED PURSUANT TO· {Specify authontyj THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
I
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes 1npaying
i!
X office, appropriation dale. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b), i
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF
D OTHER (Specify lype of modification and authority}
E IMPORTANT: Contractor Ix 1s not, I is required to sign this document and return coptes to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION {Organized by UCF sec!ion headings. including sohc1tat1onlcontract sub1ect mat(er where feasible) I
1
Excepl as p(Ov«ied here,~. all lern,s and condihoM of the document r,,f,arenced ,n rtem 9A or 10A, as herelofore changed, rema,ns unchanged and ,n full force and effect
15A NAME AND TITLE OF SIGNER (Type or print} 16A. NAME ANO TITLE OF CONTRACTING OFFICER /Type or print)
, Soo Kang
: 202-377-3798 soo kang@ed.gov
158 CON_TRACTORIOFFER00 R~---- -----" 15C DATE SIGNED

r---
I -___,,
168 UNITED STATES OF AMERICA 16C DATE SIGNED
(b)(6)
JUL 12, 2012
1 (Signature ol person authorized lo sign}

Si na of Contractin
~SN 75.JO-Ol-152-R07tl .'T.\'liD.-\RD t'OR\I 30. (Re\·. 10-83)
Pre, 1ous E<l111011unu.,ahlc Prc\crihcd by (;SA fAR (.fR CFRI 53 2~3
Supplementary Page
The purpose of Modification 0038 to Contract# ED-FSA-09-O-0014 is to provide funding for system changes
due to the legislative changes, as reflected in CR#1614 - Temporary Elimination of Interest Subsidy during
Grace Period.
The total value of the contract is increased by $71,780.00 from $148,519,578.10 to $148,591,358.10.
PAGE 2 OF 3 ED-FSA-09-D-0014i0038
-------- "'""-•.
SCHEDULE Continued
--
ITEM NO. SUPPLIES/SERVICES QUANTIT'I' UNIT UNIT PRICE $ AMOUNT $
---- -- - ·- -- -- -------
Contracting Officer: Soo Kang, 202-377-3798,

soo.kang@ed.gov
Contracting Officer Representative: Tammy Connelly,

202.377.3298, tammy.connelly@ed.gov
Technical Point of Contact:
(New Line Item}

PHEAA Legislative Changes

legislative Student Aid Changes/Neg Reg Change
(Mandatory)
0021 Pennsylvania Higher Education Assistance Agency 1.00 SE 71,780.00 71,780.00
to make changes to their servicing system due to
Legislative Changes.

0202A2012.B.2012 .ENB00000. 6CA. 2521 A.AAJ .000 _0000 000000
$71,780.00
'
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-----'-----------------~----'-- __l
__ ,.______ ~-- --J
PAGE 3 OF 3 ED-FSA-09-0-0014/0038
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT I' Coc<rnct,OCode

11
Pane of Panes
I 2 -1
2. AMENDMENT MODIFICATION NO. 3 EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 15.PROJECT NO. (11applrc.able) 1,
0039 1 JUL 17, 2012 EDOFSA-12-000550 1
I 6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6)
I Unite<l States Depart=n: ot Educalion
CODE
i
: aooForstStNE-Su~e97F3
Washington DC 20202
,_,_~oco ,s,_~_,_"_'_"_'cMc.scs-,oo=Sc°'c~c•=Ocmcoo====~==~--=--=--ce=S,ececBcl_0_~-6--~-~
!f 8. 0000 AND ADDRESS OF CONTRACTOR (NO. Street, Country, State arid ZIP Code)
NAME (X) 8A AMENDMENT OF SOLICITATION NO.
' HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS· 007368103 ~
I HARRISBURG PA 171021444 98 DATED (SEE ITEM 11)
I f--f-,-1ri'A--MODIFICATION
X
OF CONTRACT/ORDER
ED·FSA-0,-)-1):14
NO.

________________ 11"."T,t!IS ITEM ONLY APPLIES TO ~MENOMENTS
0 Of SOLICIT ATI0~ 0S ___________ _
D The above numbered sol1citatIon is amended as set forth in ilem 14 The hour and date specified for rece'rpt of offers ·,s extended, D ·,s not extended. D
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the sol1c1tation or
as amended, by one of the following methods:
/a) By completing items 8 and 15, and relurning ___ copies of amendmen1: {b) By acknowledging receipt of thrs amendment on each copy of the offer submitted:
or (c) By separate letter or telegram which includes a reference to the solicirntion and ~mendmenl numbers.
REC EIV[D AT TH EPLA CE DESI GNATED OR THERECE ,n
OROFFERS eRIORTOT HE HDURANDO A, ESPECIFIEDMAYRESULT
'
YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted, such change
telemam or letter makes reference to tne soi'icrtation and th'rs amendment, and is received onor to the ooemna
INREJEC O N OF
may be made by telegram or letter. provided each "
hour and dale soecified.
12. ACCOUNTING ANO APPROPRIATION DATA (If required)
Modification Amount· $35,000,000 00
See Schedule ModIficat1on Oblrgated Amount: $35,000,000.00
Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Spedfy authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE
IN THE
CONTRACT ORDER NO. IN ITEM 10A
' B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES
(such as changes In paying
office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b}. I
'
X MUTUAL AGREEMENT BETWEEN THE PARTIES i
~5_ OTHER (Specify type of modification and authority)
E. IMPORTANT Contractor IS not, r Ix

1s required to sign this document and return
' -
14. DESCRIPTION OF AMENDMENT/MODIFICATION 1' 0rgan,zed by UCF section headings. 1ncud ng sol1atat1on contract subj ct matterwhe
'' e
The purpose of this modification is to add funding for servicing operations. ' "' eas1ble)
2. The total contraci value Is increased by $35.000,000 from $148,591,358.10 to $183,591,358.10

3 All other terms and conditions remain unchanged
hcept as pmv,ded herein, all lwms a~d conditions of the dacument refe1enced ,n 1le,i gA o, tOA. as heretorore
changed, rem ams unchangea and rn full force and etred,
I 15A NAME ANO TITLE OF SIGNfcR l,Type or pnn1] 16A. NAME AND TITLE OF CONTRACTING OFFICER l,Type or print)
Nicholas Chung
·- 202·377-3635 nicholas chung@ed gov
RA=c•,
",0 0°a,0 o=e°FE"R"o"R
0
··-~ 15C DATE SIGNED' 168. UNITEO STATES OF AMERI 16C, DATE SIGNED
,rb)(6) -- I b)(6)
' JUL 17, 2012
(S1g11atureof person authorized to sign) iI /Skmature of Controdinn I ~------

",. --..
Otfi
NSJ\' 7~40·01 • 152-8070 '
ST A'IDARD FOR'.\-1JO. (Rev. 10-83)
Prcvrou,; Edition unusable
Prescribe<! by GSA FAR (48 CFR) .5.'l243
-----------------------------------
. ______
-·· SCHEDULE Continued
[
-~------------~----~-~----~-------!
ITEM NO, SUPPI.IES/SERVICES QUANTITY UNIT UNITPRICE $ AMOUl<IT$
- ______J__~~~----+----+----1----------L-~i
Contracting Officer: Nicholas Chung, 202-377-3635,

!
n1cholas chung@ed.gov
Primary Contracting Officer Representative: Tammy

Connelly, 202.377.3298, tammy.connelly@ed.gov
Alternate Contracting Officer Representative(s):

Patrice Washington, (202) 377-3845,
! Patrice,Washington@ed.gov
Primary Technical Point of Contact: None
Alternate Technical Point of Contact(s):

None
(New Line Item)

PHEAA Servicing Operations
0022 Pennsylvania Higher Education Assistance Agency to 1.00 SE 35,000,000.00 35,000,000.00
provide servicing operations.

0202A2012.B.2012. EN B00000.6CA. 2521 A.ABS. 000.
0000.000000
$35,000,000.00
~_J_______ __J
PAGE~ OF 2 EO-FSA-09-0-0014/0039
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT I' Coo1rncllDCode

I Pane of Panes
I 1 I 3
2. AMENDMENT MODIFICATION NO 13.EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ NO. 15.PROJECT NO (If applicable) '
0040 JUL 17, 2012 EOOFSA-12-000476
6 ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If o1her !han 1lern 6) CODE
United Sta1es Department of Educahon
Federal Student Aod.'Moss,onSupport Group See Block 6
I 830 Forst S1 NE - Suite 91F3

Washmgton DC 20202
8. NAME AND ADDRESS OF CONTRACTOR (NO., Street Country. State and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS· 007368103 (x)
~
Cage Code· 41UK7
HARRISBURG PA 171021444 9B. DA TED (SEE ITEM 11)

ED-FSA•O!W-0014
X
10B DATED {SEE ITEM 13)
D The above numbered solicitation Is amended as set for1h in item 14. The hour and date specified for receipt of offers is extended, Dis Onot extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the sol!c1tation or as amended, by one of the following methods:
(a) By completing items 8 and 15, and returning __ copies of amendment: (b) By acknowledging receipt of this amendment on each copy of the offer submitted:
or (c) By separate letter or !elegram which includes a reference to the sollc1tahon and amendment numbers FAILURE OF YOUR ACKNOVVLEDGMENT TO BE
RECE IVED AT THE PLACE DESG I NA TED FOR THE RECEIPT 0 R OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER If by virtue of this amendment your desire 1o change an offer already submitted, such change may be made by telegram or letter, provided each
telenram or letter makes reference to the sol1c1tationand this amendment. and is received r rior 10 the on~ni= hour and date snec1fied
12. ACCOUNTING AND APPROPRIATION OAT A (If required) Modification Amount $266,830.00
See Schedule Modification Obligated Amount· $266,830 00
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14,
Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority} THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO IN ITEM 10A
I
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes In paying
X office, appropriation date, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43 103(b)
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF.
I
; D OTHER {Specify type of mod1ficahon and authority)
I
E. IMPORTANT Contractor B< Is not. I is required to sign this document and return copies to the issuing office
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicI\atIonlcontract subject mailer where feasible)
The purpose of Modification 0040 to Contract# ED-FSA-09-D-0014 IS to provide funding for system changes due to lnome Based Repayment
enhancements implementation.
I
I The total value of the contract is mcreased by $266,830.00 from $183,591,358 10 to $183,858.188 10. .See Continuation Page
I
Except as p,ovK!ed here,n, all terms Md cond~•ons of the docurnenl referenced m llem 9A or 10A as he,elofore cl1anged. remams unchanged and m full force and elfecl
15A, NAME ANO TITLE OF SIGNER (Type or print) 16A NAME AND TITLE OF CONTRACTING OFFICER {Type or print)
Soo Kang
202•377-3798 SOD kang@ed gov
1
l.15B. CON!RACTORIOFFEROR_ --··- ------0 15C DATE SIGNED! 168_ UNITED STATES OF AMERICA_ __
_ 16C DATE SIGNED
I JUL 18, 2012
: (Signature of person authorized lo sign)

S1 n ture of Contra In fflcer
>-;S\i 7 540-IJJ-152-8070 ST.-\~D.-\RD FOR\130. (Re,·. 10-83)
l'rc1 ious Edition 1mu,ablc l'r~~~rib.:d h;, CiSA FAR (48 CFR) ~.12.13
Continuation Page
Continued from Block 14...
PAGE 2 OF 3 EO-FSA-09-D-0014/0040
- --
SCHEDULE Continued
ITEM NO. SUPPLIES /SERVICES QUANTITY UNIT UNIT PRICE S AMOUNT $
- - ----
Contracting Officer: Soo Kan g, 202-377-3798,

soo.kang@ed.gov

Connelly, 202.377 3298. tam my connelly@ed.gov

None
Primary Technical Point of Contact None

None
(New line Item)

PHEAA IBR Enhancements
Acquisition Plan Request Nu mber FSA000069 • TIVAS

Not-For-Profit (NFP) Service rs (Mandatory)
0023 Pennsylvania Higher Educat ion Assistance Agency to 1.00 SE 266,830.00 266,830.00
provide enhancements for th e IBR initiative.
Accounting and Appropriatio n Data:

0202A2012.B.2012.ENB000 00. 6CA.2521 A.AAJ. 000.
0000 000000
$266.830.00
I i
I
I I
I
i
'
I
I
I
I
'
I
I
I
-I
PAGE 3 OF 3 ED-FSA-09-O-001410040
1 Pane of Panes
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1 c,o1,,,t1oc,,,
I I
2. AMENDMENT MODIFICATION NO. 13. EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO.
I'
1
PROJECT NO. {if applicable)
3
0041 JUL 19, 2012

6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE
Federal Student A1d/M1ssion
Support Group See Block6
Washington DC 20202
~
Cage Code: 41UK7
HARRISBURG PA 171021444 9B. DATED (SEE \TEM 11)

ED-FSA-09-D-0014
X
1DB. DATED (SEE ITEM 13)
D The above numbered solicitation is amended as set forth in item 14. The hour and date specified for receipt of offers D is extended, Dis not extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended. by one of the following methods:
(a) By completing items 8 and 15. and returning __ copies of amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;
or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
te!enram or letter makes reference to the solicitation and this amendment, and is received "rior to the O"enin" hour and date S"ecified.
12. ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: $-19,930.00
See Schedule Modification Obligated Amount: $-19,930.00
Check One A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO. IN ITEM 10A.
X office. appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103{b),
E. IMPORTANT: Contractor Ix is not, I is required to sign thls document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible)
The purpose of this modification is to de-obligate $19,930 from Modification 0040 of contract #ED-FSA-09-D-0014. The modification changes the
total value obligated towards system enhancements for Income Based Repayment implementation from $266,830 to the new total of $246,900 .
Over all total contract value changes ... See Continuation Page
,' E~cept as provided herein, all terms and conditions of the document referenced ,n ,tern SA or 10A. as heretofore changed, remains unchanged and ,n full force and effect.
15A. NAME AND TITLE OF SIGNER (Type or print) I16A NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
,
1
Soo Kang
:202-377-3798 soo.kang@ed.gov
I
15B. CONTRACTORIOFFEROR , 15C. DATE SIGNED 168. UNITED STATES OF AMERICA 16C. DATE SIGNED
b)(6)
JUL 19, 2012
(Signature of person authorized to sign}

e 01 c:on rac,m I
NSN 7540-01-152-8070
' " t...____../sT
AN DARD FORM 30. ( Rev. 10-83)
Previous Edition unusable Prescribed by GSA FAR (48 CFR) 53.243
Continuation Page
from $183,858,188.10 to $183,838,258.10.

All other terms and conditionsremain unchanged.
PAGE 2 OF 3 ED-FSA-09-D-0014/0041
SCHEDULE Continued
ITEM NO, SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE S AMOUNT S

soo.kang@ed.gov


None

None
(Changed Line Item)

PHEAA IBR Enhancements
Acquisition Plan Request Number FSA000069 - TIVAS

Not-For-Profit (NFP) Servicers (Mandatory)
0023 Pennsylvania Hlgher Education Assistance Agency to 1.00 SE 246,900.00 246,900.00
provide enhancements for the IBR initiative.

0202A2012 .B.2012. EN 800000 .6CA.2521 A.AAJ .000.
0000.000000
$246,900.00
PAGE 3 OF 3 ED-FSA-09-D-0014/0041
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 11.Contract ID Code

~~~~f1a
I
2. AMENDMENT MODIFICATION NO. 13. EFFECTIVE DATE 4. REQUISITION/PURCHASE REO. NO. 15.PROJECT NO (if app!icable}
0042 AUG 08, 2012 EDOFSA-12-000642

' 6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE
Unite<:!States Department of Education
Federal Student Aid/Mission Support Group See Block 6
830 First St NE - Su,te 91F3
Washington DC 20202
~

Cage Code: 41 UK7

EDHA-ll9-D.(){)14
X
I CODE 00030774 I FACILITY CODE JUN 17, 2009
D The above numbered solicitation is amended as set forth in item 14. The hour and date specified for receipt of offers is extended, Dis Dnot extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of the following methods: I
{a) By completing items 8 and 15, and returning __ copies of amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;
or {c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
telenram or letter makes reference to the solicitation and this amendment, and is received nrior to the O"enin" hour and date Snecified.
X office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b}.
D OTHER (Specify type of modification and authority)
! E. IMPORTANT: Contractor fX is not, I is required lo sign this document and return copies to the issuing office.
I The Purpose of Modification 0042 lo Contract #ED-FSA-09-0-0014 is to provide funding for processing the Special Direct Consolidation Loans as
1
implemented by CR#1550.
The Total Value of the Contract IS increased by $5,500,000 from $183,838,258.10 to the new total of $189,338,258.10 ... See Contmuat1on Page
E~cept as provided herein. all terms and condct,ons of the document referenced in ,tern 9A or 10A. as heretofore changed, remains unchanged and in full force and effect
15A. NAME AND TITLE OF SIGNER {Type or print} 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
Soo Kang
202-377-3798 soo.kang@ed.gov
15B CONTRACTO"R,1,0,F,FoEcR,DcR~-----------l 15C. DATE SIGNED 16B. UNITED STATES OF AMERICA 16C. DATE SIGNED
(b)(6)
AUG 08, 2012
(Signature of person authorized to sign)
NSN 7540-01-152-8070 fANDARD FORM 30. (Rev. 10-83)

Previous Edition unusable Prescribed by GSA FAR (48 CFR) 53.243
Continuation Page
PAGE 2 OF 3 ED-FSA-09-D-0014/0042
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT PRICE $ AMOUNT$
"'"
Contracting Officer: Sao Kang, 202-377-3798,
soo.kang@ed.gov


Tammy Connelly, 202.377.3298,
tammy.connelly@ed.gov

None
(New Line Item)

Special Direct Loan Consolidation Processing
Acquisition Plan Request Number FSA000060 - Title IV

Additional Servicers (TIVAS) POS LC
MAX
0024 To provide funding for Pennsylvania Higher Education 1.00 SE 5,500,000.00 5,500,000.00
Assistance Agency to process Special Direct Loan
Consolidations.

4253XNOYR.B.2012. EN 800000.A 16.2521 A.AAG .000.
0000.000000
$5,500,000.00
OBTAINED BY STUDENT BORROWER PROTECTION CENTERPAGE 3 OF 3 ED·FSA-09-D-0014/0042

AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
I AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT j

i
1
Contract ID Code r~~-9l_rag;
2AME:Ncii.:fEN·fMODIFICATION NO I 3. EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO I5 PROJECT NO. {1f applicable)
0043 ''
I AUG 10. 2012 I
6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other than item 6) CODE
United States Department or Edu<;alron
Federal Slunent A1dlM1ss1on Support Grnup See Block 6
830 First St NE - S<llte 91 F3
Wash1t1ytun DC 20202
~---
8 NAME ANO ADDRESS OF CONTRACTOR (NO Street Country, State and ZIP Code) 9A AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS: 007368103 (>)
~
Cage Code 41 UK?
I
' HARRISBURG PA 171021444 9B. DATED iSEE ITE'M 11)
'
' '
ED-FSA-09-D--OCl4
X
11. TH\S ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
D The above numbered solicitation Is amended as set forth In ,tern 14. The hour and date specified for receipt ol offers D Is extended, Dis not extended.
Offers must acknowledge receipt of \h,s amendment pnor to the hour and date specified in the solicitation or as amended, by one of the follow,ng methods.
(a) By completing items 8 and 15, and returning ___ copies of amendment: (b) By acknowledging receipt of lh1s amendment on each copy of the offer submitted.
or {c) By separate letter or telegram w'l1ch includes a relerence to the sol1citat1on and amendment numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE '
RECEIVED AT THE PLACE DESIGNATED FOR THERECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF '
YOUR OFFER If by wtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter provided each
telenram or letter makes reference to the sol1c1tation and this amendment, and Is received enor 10 the oeenrng hour and datEl_~c1fied
Modification Obligated Amount: $0 00
See Schedule 1
'
Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO (Specify autiiOrity) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO IN I·1EM 10A.
;
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes In paying
;'
-
X office, appropriation date, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.1 03(b).
- --- ------------
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF·
i
'
' D OTHER (Specify type of mod1ficat1on ,md authority)
I
' E. IMPORTANT: Contractor IX is not, I is required to sign this document and return copies to the issuing office.
14 DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, 1nclud1ngsoiicitauonlcontracl subJect matter ,11herefeasible)
See Attachment Page
I FxcPp! as ;,rw,ded '·""''"· all terms a 0 d con<lrt,oosof !he Oocum~nl refore11cad,r. ,:em 9A er 1GA. as t,~,etufute changM rema,ns unchanged and rn fl.JII!oice aM effect.
1
15A NAMEAND TITLE OF SIGNER (Type or print) 16A NAME AND TITLE OF CONTRACTING OFFICER (Tyoe or pnnt)
Victor Cairo
202-377-3814 Victor Ca1ro@ed gov
'.
15B. CONTRACTORIOFFEROR ! 15C DATE SIGNE~J--16B UNITED STATES OF AMERICA_, __ . 'T 16C DATE SIGNED
b)(6)
(b)(6) I AUG 10, 2012
(Signature of person authoriled to s;gn)

, na ure o on rac ,n Icer
NS-.: 7540-lll-I52•~070 STAND-\RD FORM 30. (Rev. 10-/l3)
Prev,o,isEdit,l'n unu.,,1hl~ Prescribed by USA FAR (48 CFR) 53.243
Attachment Page
The Purpose of Modification 0043 to Contract IIED-FSA·09·D·0014 is two parts:
l. To incorporate the following clauses. (See att.ichmcnts)
a. FSA 25·1 Prohibitions on Contract Performance Outside of the United St.ites (JULY 2012)
(Replacing clause B 13IJ) Work Performed Outside the Continental United States)
b. FSA37-2 !JULY 2012) Continuation of Mission Critical Contractors Services
c. FSA39-l Reporting Requirements for Department Contractor Employees Alternate I

IAug 2012)
d. FSA42·1 Po,tAward
2. To designate Lynn Smith as Secondary Alternate Contracting Officer's Representative (CORI for
contract #ED-FSA-09-D-0014:
Lynn E. Smith
Contracting Officer's Representdt,ve
Federal Student Aid
Business Operations
830 First Street NE, Rm 63H 1
Wash;ngton, DC 20202
202 377-3577 (Direct)
202 275-0492 {Fax)
I ·inn s,,,ith@ed.rciv
All Other term, end conditions remain unchangE>d.
PAGE 2 OF 8 ED-FSA-09-D-0014/0043
Attachment Page
FSA25-1 PROHIBITIONSON CONTRACTPERFORMANCEOUTSIDEOF THE UNITEDSTATES(JULY2012)
The Contractor has represented to the Department that 1twill perform all work required under this
ContrJct within the United States. If, at any trme, the Contractor wishes to perform any Contract work
outside the United States, the Contractor shall inform the ContrJcting Officer, ;n advance and in writing,
of its 1ntent1on and request the Department's approval. The Contractor shall not perform ,my Contract
work outside the United States unless and until it has received the Contracting Officer's explicit, written
approval to perform such work. In order to give proper consideration to the Contractor's request, the
Department m;ayask for, and the Contractor shall provide, information relevant to the proposed
performance oubid~ th~ United States, including but not limited to a detailed d<"srnption of the
physical, personnel and management resources to be used and any potential difficulties or constraints in
performing In the foreign 1umdict1on. The Department may refuse to approve Contract performance
outside the un;ted States to the extent that, solely in the Department's judgment, the Contractor h,is
not >hown that performance out,,de the United States would sat,sfy the Contract requirements and
would not impair or degrade performance. further, the Department may refuse to approve any
performance outside the United States for any other reason, or for no reason, e~cept as otherwise
required by the laws and treaties of the United States. The Department mav approve performance
outside the United States subject to certain conditions, to which conditions the Contractor shall strictly
adhere. Neither performance within the United States, nor the Department's refusal to allow
performance outside the United States shall ever constitute a change to this Contract or give rise to any
entitlement to additional compensation or excuse any failure of performance by the Contractor.
Nothing 1n this clauoe shall be interpreted to impose any obligation on the Department to allow or to
refuse o request for performance of this Contract outside the United States.
PAGE 3 OF 8 ED-FSA-09-D-0014/0043
Attachment Page
FSA-37-2 (JUL 2012) CONTINUATION OF MISSION CRITICAL CONTRACTOR SERVICES
(a) Defmit1on. As used in this clause-
(1) Mission Critical Contractor System or Other Services are defined as a system or other
services that have a material impact on the accomplishment of the Federal Student Aid mission.
fb) The services under this contract are vital to the mission of the Department of Education IED). The
Contractor shall be responsible for the availability of all systems operated, or other service; performed
by the Contractor for ED, regardless of location. This clause applies to all or any part of the contract that
includes ,ervIces that directly support the agency's mission.
(c) The Contractor shJII provide, implement, and maintain a Continuation of M1ssIon Critical Services
Plan for contInuIng performance of services no matter the circumstances. The PIJn sh;:ill describe the
proce,se1 and procedures that will be followed to ensure continued availability of services under this
contract. Any alternate site used as part of o;saster Recovery shall be fully operational within~
of a declared disaster. The Contractor shall identify in the Plan the provisions made for the acquisition
of mission cr1trcal personnel and resources, if necessary, for continuity of operations for up to 30 days or
until normal operations can be resumed.
{,!)Within 30 days after contract award, the Contractor $hall submit for approval it; Plan, which shall be
consi1tent with and further detail the approach contained in the offeror's proposa! The Pl.m, as
approved by the Contracting Officer, shall be incorporated into the contract as a comphance documerlt.
The Plan mu;t, ~ta minimum, address:
1. Name of company's officer overall responsible fort he maintenanct>, management, exercisin~

and execution of the Plan,
2. Plans and procedures;
3. Identification of mission critical functions;
4. The time lapse a»ociJted with the initiation of the acqu1sit1onof rrn1;ion cr:tical personnel and
resources and !heir .ictual availability on site;
5. Dele~at1ons of authority, planned order of succession, and cross-traI11Ingto ensure per1onnel

are aVJll"blc to provide srrviccs and make key decisions;
PAGE 4 OF 8 ED-FSA-09-D-001410043
Attachment Page
6. Proposed alternate operating facilities, interoperable, connectivity and emergency

communication, approach;
7. Cntical records or d~ta storage procedures,
8. Protection of human capital;
9. Testing approach for ~annual test a year,
10. Training plan,
11. Delegation of control and d,rect1on,
12. Reconstitution and resuming normal oper.itions plans; and
13 Schedule for periodic review and revision, of Plan
{I) The Contractor shnll maintain and update its Plan as necessMy and adhere to its requirements
throughout the contract term. The Contractor shall not materially alter the Plan without the Contracting
Officer's written consent
{g) As dorected by the Contracting Officer, the Contractor shall participate and collaborate with ED and
I1scontractors ,n training events, exNcIses, and drills associated with Government efforts to test the
effediveriess of continuity of op orations procr-dures and practices with internal and external entItIes.
R.esul~sof the exercises shall be dtlivered to the Contracting Officer or other de11gnated representative
within 30 days alter the e~ercise.
(h) In the event the Contractor anticipates not beine able to perform any of the mission critical
contractor services identified in the paraeraph above, the Contractor shall notify the Contracting Officer
or other designated representative immediately and use its best efforts to cooperate with the
Government in the Government's efforts to maintain the continuity of operations In no way doe, (h)
relieve the contractor of financial responsibility in m"eting the contr,ict term1 and conditions
(i) lhe Government reserves the right to uo;eFederal employees of other agencies or support from other
parties or to enter into new contracts for nmsIon critical contractor services. Any new contracting
efforts would be conducted in occordance with OFPP letter, "Eme1 gency Acquisitions" May 2011 and
FAR PJrt 18, respectively, or any other subsequent emereency guidance isrned.
(j) The Contr~ctor ,hall include the substance of this clause, including this paragraph {j), in subcontracts
for the mission critical services.
PAGE 5 OF 8 ED-FSA·09-D·0014i0043
Attachment Page
FSA 39-1 Reporting Requirements for Departed Contractor Employees Alternate I (August 2012)
{a) As part of security clearance processing, the contractor ,s required to notify the Government no later
than the end of th,:, business day on th,:, day a i;ontractor employee proposed for or Jwarded a security
clearance under this contract or memorandum of understanding departs employment under this
contract or memorandum of understanding. To meet this requirement, the contractor shall send an
encrypted email ta FSAPersonnelSecurity@ed.gov and OMPersonnelSecurity@ed.gov with a carbon
copy to the Contracting Officer, Contracting Officer's Representative, and Information Security System
Officer The contractor will be advised under separate communications of the encryption password
sthematics that must be followed in reporting under this clause, The subject line of the email shall read
"Departed User", and include the following rnformat1on:
Employee Last Name, h,t Name
eQIP number, 1favailable
Date emp'oyee hired under the contract or memorandum of understanding
Contract or m<:morandum of understanding number
List ot systems to which employee has access
lb) In addition, the contractor is required to identify those employees recommended for or awarded d
security clearar,~e under thi, contract, who departed employment within the past 30 (thirty) days The
contrJctor ;s reqciired to send an encrypted email within 5 {five) business days after receipt of this
modification to FSAPersannelSecurity@ed gov and OMPersonnelSec<,r1ty@ed.gov with a carbon copy \o
the Contracting Officer and Information ~ecur1ty Systems Office The subject line of the ema·1 shall read
"Departed User", and include the following information:
Employee Last Name, First Name
eQIP number, if available
Date employee hired under the contract or memorandum of understandmg
ContrJct or memorandum of understandrng number
List of systems to which employee has access
The submission of information detailed in paragraph (bl 1, a one-time effort, and thereatter reporting
shall be made wm1stent wrth paragraph (a).
PAGE 6 OF B ED-FSA·09·D-0014/U043
Attachment Page
FSA 42-1 Post Award Evaluation of Contractor Performance !JUL2012)
Interim and final evaluations of contractor performance will be prepared on this contract
in accordanle with FAR 42 15, The ;y;tern utili;:ed to record past performance evaluations is the
Contractor Performance Assessment Reporting System (CPARS),which 1sa feeder system for the Pa;t
Performance Information Retriev~I System (PPIRS) The Contractor shall designate a CPARS
Representative to administer evaluations tor the Contractor. The Representative sha:1be responsible
for rrview1ng and ,ommenting on proposed ratings and remarks for all assessments forwarded by the
Contracting Officer. The r1r1t Interim CPAR report shall be assessed after 12 months of rontract
performance, with Interim reports as,essed every 12 moriths thereafter. If the award value is over the
Simplified Acquisition Threshold, and the p<cr1odof performance 1sshorter than 12 months, the
evaluation shall be a;1essed ;it the completion of work. The Contractor will be permitted thirty (30)
days to review the evaluation and to submit add1t1onal information or a rebutting statement in CPARS.
If the Contractor does riot comment during the review period, !he report shall be fin;:,lized after (30)
days. The Final contract performance evaluation will be prepared at the time of completion of work.
Any disagr!c'ement bctwe~n the parties regarding an evaluation will be referred to the next h1gher level
above the Contrdcti11g Officer, whose deci,ion will be final Copies of the evaluation, contractor
re1ponses, and review comments, if any, will be retained as part of the contract file, and will be used to
support future award decisions. Copies of completed evaluations can be obtained in CPARS and PPIRS.
PAGE 7 OF 8 ED-FSA-09-D-0014/0043
·- -~-·--·-·-------~~-= --------------------------~
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES
----·-·~·--- -----,,.--.-,-,rr-
..-.. -"-"-,----c-.-,,-,-,-"-,-,--
-! -c·--,-.-,-c-_,-,-
i -~--------+--------,
Contracting Officer: Victor Cairo, 202-377-3814,

Victor.Cairo@ed.gov
1
Primary Contracting Officer Reprosentnt1ve: Tammy

Patrice.Washington@ed.gov
'Primnry Technical Point of Contact: None
Alternate Technical Point of Contcic!(s):

None
PAGE e OF 8 ED·FSA-09-D-0014/0043
I 1 Contract ID Code Pa~_ of 1--'ages

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1 I 3
2 AMENDMENT MODIFICATION NO 3 EFFECTIVE DATE 4 REOUISITIONIPURCHASE REQ NO. 5 PROJECT NO (1/applicable)
0044 SEP 11 2012 EDOFSA-12-000691

~~~~-------==·[
6 ISSUED BY CODE F0 S0 A~-F
0 0
S 2~----+c,-A'D 0
M"<N',"s"r"e=RED
BY (If other than ,tern 6) -~c"o"o"E--
l.'n1ted S:a:es Cepartmem o, Ec•JCat,cn
Federal Student A1 □1V1ss1or. SLlppor. Group See Block 6
330 Cirst St "E Suite 91 F3
Wash,ngton DC 20202
8 NAME AND ADDRESS OF CONTRACTOR (NO Street Country. State and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA DUNS 007368103 ,_(X)
1200 NORTH 7TH SrREEf Cage Code: 41UK7
:::INANCIAL MANAGEMENT 5TH FLOOR
:7ARRISBURG PA 171021444 9B DATED;SEEIT[M11)
10A MODIFICATION OF CONTRACf/ORDER NO

EJ-'S'--•:9-~-Jo· 4
CODE 0003077 4 I FACILITY CODE JUN 17, 20C9

11. THIS ITEM ONLY APPLIEs_i:o AM~N_DMENTS Of SOLICITATIONS
D fhe above numbered sol,c1ta!ion Is amended as set forih In item 14 The hour and date specified for receipt Jf offers D Is extended, 01s not extended
Offers must acknowledge rece,pt of this amendment prior to the hour and date specified 111 !he sol1citat1onor as amended. by cine of the followmg methods·
iaJ By completing I<ems 8 and 15 and returning ___ copies of amendment {bl By acknowledging receipt ol lh1s amendment on each copy of the offer submitted,
or tcl Ry separate letter or telegram wh,ch includes a reference to the sol1c1tat1onand amendment numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECE:IVED AT THE PLACE DESIGNA1ED ~OR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATC: SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER If by vIr1ue of this amendment your desire \o change an offer already submitted. such change may be made by telegram or letter provided each
'.elegram or letter makes reference to the sol1citat1onand this arn~ncl_'!7enl.and is received p11orto the opernng hour and date spec1f1ed
12 ACCOUNTING AND APPROPRIATION DATA (If required) ModIfIcatIon Amount: $7,575 000 001
See Schedule Mod1f1cat1on Obligated Amount $7 575.000 00!
13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED !N ITEM 14.
I Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO (Specify authoriti,,) THE-CHANGES SET !'ORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO IN ITEM 10A
B THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes ,n paying
office appropnat1on date, et CJ Sf r l'ORTH IN IT EM 14, PURSUANT rQ THE AUTHORITY OF FAR 43 103(b)
C THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANr JO AUTHORITY OF
------+-c-~~----------------------------------------
0 OTHER {Specify type of modification and authority)
X Funding Only Action
E IMPORTANT Contractor IX Is not. I Is required to sign this document and return copies to the IssuIng office.
14 DESCRIPTION OF AME'NDMENT1MODIFICA TION (Organ,zed by UCF section headings. 1nclud1ngsol1crtat,on/contract subJeC! matter where feasible)
The purpose of this Mod1ficat1on 0044 ;o Contract Number ED-FSA-09-D-OO 14 Is to provide funding as described below
1 Funding for servIcIr.g operations in :he amount of S7.200.000.

2 Funding for system enhancements In the amount of$375,000. See Continuation Page
~,.~r, as pmvIdc_dhc·cin al. ter·~s and conc,t,ons of the docurnenl refe,enced ,,o ,1ern9f, or 1M, dS heretofore d1ar1geG reJJ•a111sum:11,mgeda11d,~ full furce ,rnd ef'eLI
15A N/\ME AND TITLE OF SIGNER (Type or pnntJ 16A NAME ANO TITLE OF CONTRACTING OFF1CER (fype or print)
Soo Kang
202-377-3798 soo ~ang@ed gov
156 i:::6Nff/ACTOR/OFFCR0R-
---------~
'
15C.DATESIGNED. 166 iJN1Jt.OSTATESOF-AMERICA
rb)[6) L 16C DATE SIGNED
SEP 11. 2012
\Signature of person authorized to sign)

(S,gnatllrC of Contract1n i'.Jrncer)
'\SN 7S--\11-11l-lS:-~rn1 ST.\.'\D.-\RD FOR:\1 JO. (R'-''· 10-/BJ
['re, l(lllS l.di11on unu,,ibk l'r~s,nh~d b'.' (,',.-\ 1--\R (--lS CI--RJ S3.~--\J
Continuation Page
Continued from Block 14 ...
3. The total contract value is increased by $7,575,000 from $189.338,258.10 to $196,913,258.10.
PAGE 2 OF 3 ED-FSA-09-D-0014/0044
SCHEDULE Continued
--1 I
ITEM NO SUPPLIES/SERVICES
!
QUANTITY
! UNIT UNIT PRICE S
AMOU-~~s
Contracting Office:· Soo Kang. 202-377-3798,

soo.kang@ed.gov

Alternate Contracting Officer Represental1ve(s)·

Patrice Washington, (202) 377-3845.
Patrice.Wash1ngton@ed.gov
Alternate Technical Point of Contact{s):

None
(New Line Item)

0025 Pennsylvania Higher Education Assistance Agency to 1.001 SE 7,200 000.00 7,200,000.00
provIce servicing operations.

0202A20 12.B.2012. ENB00000. 6CA.2521 A. AB5. 000.
0000 000000
S7.200,000.00
{New Line Item)
!
0026 Pennsylvania Higher Education Assistance Agency to 1.00 SE 375 000.00 I 375.000.00
provide enhancements to their servicing system.

0202A2012.B.2012 ENB00000.6CA.2521A.AAJ 000
0000 000000
S375 000.00
PAGE 3 OF 3 ED· FSA 09-D-0014/0044
1. Contract :o CJde :_ages,f ~ag_e_s

_
6
2. ArvlEC<DMENT MODIFICATION NO. 3. EFFECTIVE DP.TE 4. REQUISITION/PURCHASE REQ NO 5 PROJECT \10. If ap~•1cable)
OC45 SEP 17. 2012 _l_

,-5:·is•s••u•,•o•••s•,~----------cc•o•o•,~-FSA-FS2 --c•·•0•0•,-----------
--+•,~A•o•,-.,•"•,•s•T"E"R'E"DccB•ycc,c•,•,-,-,-,,•,-,-,-,•,,-m-,e,
u,,,1~c s·ates Deoa,tmer: cf Ea•,cat,o~
,·cjccal St Jdent A,a.'M,ss;on Suppo~ Group See Block 5
SJC Firs'. S: NE - Serie 9T3
·Nasring:~c DC :czc-2
8 NP.J,1~-C::NlJ
A)DRC:SS OF CON[qACTOR :NO Stree!, Countr,,. State and ZIP CodeI 9A AMt:ND 1,1t::f'il OF SOL CITATION NO
(x)
HICH::'R FDUCATION ASSISTANCE 1\GENCY. DUNS 007368103 --
PENNSv~\lf,.NIA Cage Code· 41UK7
1200 "JORTH 7TH STRE'':'T C------------ -------------
9B. D-"Tc':D (SEE ,TEM 11)
FINt-.NCIAL \IANAGEMEN": 5Tl-1::'~OOR
:--iARRISi3U:'<G PA 171021444
10A MODIFICATION ::JFCO!\TRACTIORDER NO.
ec fs;.. GJ-J-c;i,.
X
108 !JAfED (SEE ITEM 13)
CODE OC030i'74 ! FACILITY CODE JUN17.20J9 I

11. THiS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
D The a:Jo,c nur-i'.x,rcd soI;c1tatio'.lIs a;rPnded as set forth in item 14 The hour and date specified for receipt of offers D Is extended. D,s not extended
Olfers ,nust acknowledge rece-pt of t:11samendmml! prior to the hour a~d date specified m the sol1citatIon or as amended. by one oi tre '.ollow1ngmethods·
(a) By ccrrp etIng items 8 ~nd 75, and retu.n.ng _____ copies of amendment; (bi [ly acknowle6g1ng receIp; ofth1s ame~dment on each copy of the offer submitted,
o, :c) By separate letter or te'egram wh,Gh i:icludes a (eferei.ce to t~e solIc,tatIon and amendment numbers FAILURE OF YO'JR ACKNO\IVLC:DGMENT ~o BE
_qECFl'/t'J A.TTHE c'LACc: DE::SIGNAIED "CR HI[ Rf:CEIPT CR OFFERS PRIOR TO THE HO'JR AND JATE SPECIFIED W,Y RESULT ON'<.EJECTION OF
YOUR O~F':R. lfby virtue oith1s amendment your jes1re to changE an otter already subrrntted such cha~ge rnay be made oy telngr;im or letter, provided each
. :elegrdm or let1!2_~"1akes ~~-~-~-~~==
reference to the sol1c1tatwnand this amenarrem and is received pnor '.o '.he opemn-:,ihouc'c'c'c''-"''""'"'"''''''1f,esdc.
, 2 ACCOUNT:NG .'\ND ,SPPRCPRIATION DAT A (I( required) M:id1f1ca(ion A'77ount $0 00
See Scncdule Mod1f1cat1on OblI:;iated A:nount: S0.00
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
1\ THIS CH1\NGE ORrnCR IS !SSUEO PURSUANT TO. (Specify authority) THE C!0ANGES SEI FORTH IN ITEM 14 ARE IMDE IN THE
CONTRACT ORDFR NO IN ITEM 10A
--------1-,~~,c,s.,cc,,:GOVE:: NUMBERED CONTRACT/ORD!cR !S MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES Isuch as changes 1npaying
o""ce, opprup,iatron dale, etc) SET FORTH l~I ITC:M 14, PURSUANT TO THE AlJTHOfoTY OF FAR 43.1 03ib)
C. THIS SUPP•_EMEN ,.t,,LAGRH:MENT IS ENTERED INTO "URSUANT TO AUTHORIJ'Y OF.

X MUTUAL AGREEMENT BETVI/EEN THE PARITES
D ·-6THC:R (Spec;fy type of modification and au:tiamy)
._ ______ ~--=----------------------- ~----·

E IMPORTANT' Contractor I is no\. IX is required :o sign !his document and return~- copie~to :he issuing office.
14 OESCRIP~I0N :)I AMEND)JIENTlf110DICIC/I TION (0rg3ni?ed bf UCF section headings. inctudrng sol.citation/contra~ s~~;ecl rnatter wl1ere feasible)
Tl>o purpose of this Mcd1fication 0045 to Co1traci Numbor ED-FSA-09-0-0014 is to add 240 add1t1onal Persoral Identity Ver•f1ca\;ori (PIV) Tokens
as Government Furnished Property (GFP,i In accordance w1tr the Terms and Conditions oft1e Contract.
See Contm~at1on Page
SEP 18, 2012
[Signature of person author,zed to sign)
\.:-iN 7)-10-\11-1'2-8070 -..._,,,S

l'.\'IIJ.\H.D l·OK\l JU. \Rn. 10-83)
l'rC\inr,:, l'Jili,,11 ;u11ro~['l~ Pr~,,rnbccJ b; (i'> \ F \R (-18 CTR) 53.213
Continuation Page
The serial numbers of the tokens being added, per this Modification 0045, are listed in Attachment 1 to
Enclosure 1
PAGE 2 OF 6 ED-t'SA-09-D-00~4/0C45
:.ttachment Page
f!ldosart' l
( ont, :1r:,,,· ;;u, ,:n1m~111l'n,perty \lanagcr: \1rn K1111mccl
Co11tr,1l'l >11,ll!JH: I·'[) l·S.,\-IJ').l).(i(l)"½
:·17_,I ,Tl '-:_~n" ID Pw1c·c·1i,,r1Pc'r~,rna; identity V,Ti lirnll<'ll ( l'I\") ic)lcns <ll\' h, ·ing 1%t1CLi
to lhc
lll all ,ier~onnd "ho suppLJ1·:!he· .::,,,, c-m,·rni,1nc,1 u111trad.
['l"l\!:,•:"_, 1·.u:1.1,:c1·J\,1ra,,1 ;n!llcnt
~ ',' ,,_ll,lclil11Cl7: i :Dr 'C'I1:1!numbns elf l]x: h1ku1:, l1ci11g,,:,ueJ ,_oLh~co11L1·<!C'.c'I·.
Cnn!rnctor Go,rrnmcnt Property ',Lrnagcr's Signature:
l~(b-)(-6)---------~L
PAGF] OF 6 ~l).iCSA-Q9-D-0o,~:oc45
Attachment Page
!,'IV-86E □ .:.rno7 ;A'-,:d66b.::.G502 AI/T85E60~009 il.\'T36664l904 A'vT86G541~02

:AV:%6640990 T,\\/T85664iJ4)3 AVTS5661),;991 AVT866541890 :A'/T86G6413~8
IA'r86G64098l IA\/T866640480 AVT86660,:983 AVT8666•1:ss· :r,.vTS56641 <so
:,o.v-86E6-<0973 iAVT85664047: A\/T86660~975 N/T866641873 IA'✓T856641371
·;w-s666~0965 :A\;fSGGG404G3 ,\VTSC;GGQ.:;.967 ,\\/T866641865 AVT866641363
,WT866540957 [AVr:-lb6[,4\)455 Av~ss55049S9 IA'v'T856641SS7 AVT86GG4E5S '
.tJ.Vr86G64(J949 !AVT8665404!:7 AVT856£049,12 ,!AVT8666,:1S49 AVT866641247 I
,\VTS65640932 IA\/1866640439 AVT856604934 ,;\VT85GG,il832 A'/T866G-11339
,;·,· r86b640924 IA\JTS66E40422 1l,.\iT856E04926 ;WT866641824 :AVT866641c72
I
AVT86G6409"G !,:..\/-,-86b64{}414 IA'•/T86660-1918 A'.'r866641S16 r.'/T8666,123:4
IAVT866640908 1A', T8566,il·11J5 !,WT856604}JO A\/T8G6G41808 :AVT8GGG,~~30G
1,wrn06640~93 A\/f8566 11C391 l,\VT856604335 ,\VT8666.J17J3 ;A\/f36GC'<l291
1;;\;:;.8666,10885 AVT8566i.C3S3 iA-:.'l8SCGO,'i88l f,VT86b5417d5 AVT8666tl1C83
1
,/\\JT866C40877 A',,TJSG6,1C37S ;\\IT85660•lS79 A\11866541777 i"',VT866541275
A\·-8~6640859 ,i.1_,f8S6640367 l,\\'T8·56(i04852 ,Wf8GGG417~9 ,WTSGGG41267
f,V":%6640852 'I.VT3SG64CJ5'l ,\VT3SC504354 AV1'8b66417'2 WTS5fi641259
---~
i•\V-,-86(;640844 ~VTS&664G3..'.;2 "',VT.%660484G A\/T8GG641744 4.VTS566411<12
:, 1,>8GGG1J003G ,WT3S,i64C33,; A'-JT3~6SOt,8J8 I\\/TS5664l736
------~
WT85S641234
A\'~366548828
-------
,\\JT8S6G,tCJ26 .>.VTt06GC4820 iAVT8GG641728 '\VT856641226
I\V":3666,JOSlO :1,Vl856610318 iWT3S668481 l !,WTH~6641710 :1-vT8JGG412.l3
A•i7866540hC1 ,i's\lT8C-GG4U3IJ0 IA',T3566C•13C-3 ·WT8566t.1701 WT866G41200
1t,V73665½0797 'c..vT~f66102S5 ,>.VTBS!o60.J799 ;il.V1SjGG,: lb~7 j WT3S56411~5
4\/Tli60Uf,Q739 !,\\ITSE6640287 ;,lV'!"8·5660•1782 !,WT856641G8g i1<VT%i:h11187
'"-"
:,\ 1iT%G540/72 !_.l.l'T866640279 :,\',/ f8CCG604
77t A\/T8S66/41672 :\1-'T8666<:11/g '
'A\ITEGGS4Q764 • .'\\ T8SS5--l02fi2
1 A'/TS,55604766 il'JTS65641664 ;117866641162 '
",VTS65:i407C6 ;\VTSGG6402'.A ·Avrn,:>G604758 •WT865641656 -WT866541154

A\/T86S5,107•18 ,'.VTS65640246 AVT8t356047.JO 1"/T866641648 WT866541 1 46 I
;,,\,1.s,:sc,-10730 ,'\\'"'."86664:)238 iJ,Vfhi:iS604731 A\/T86551Jl630 w-:-S6564ll38 I
,SVT8GGG~0721 A\'~35~5,::)220 ,r,VT865604723 A\IT86GC41621 WT866641120
'1,W":8ciSQ,;OfB ,4,\1";8656.::.~211 :t,,vrs,,:,504715 A\1-866541613 XV7866641111 'I
iAV<26S64ll70S !AVT36C64:J2U3 il.VT81)5604707 AV-86G541605 l,VT866641103
!AV":865[,/20G92 l;\\'~8G&6.::.Q:95 A\/T%Go1J46% AV""'."8661:<'i:592 l.VT866641099
;1\VT8566l:G84 l,",\'T%€6~::J~R2 AVT%550°1688 ;N:-866642584 '.\,1T8GGS41082.
jAV:866040676 !A\'TdGt6~0074 AVT866GOl.67C ;..,rs6~t41S75 '.l.\/T866S41074
-
,,\V'"~666l8668 !A'-!73666~0166 ,'.\VT%66G4ci61 AVT366S41568 WT8E6Ci.11066
----~· c_;___
r,VT86ci5~0650 ,\"s.'T866G.::.o
'58 iWT%66C4653 A\17866541550 l.\lTS6GC,410S8 I
!A\1TSG6Gi.J541 A'/T866G40~l\O ,\VT%GG04G4S iAVTSG6f4l541 WTE666410~0
-
;,,v:8G6Gi0633 X--,T3666~.Jl31 ;l,VTS1,66C4637 iAVT8G6541533 WT8~66411!31
L.:'_~·TSG65.-J~G25 ,\VT866540123 t,VT8CG50~C29 ]AVTSGb~-\1525 .\\'T8656,11023
.WT865C4'.JG17 ,\\, TS5654.J115 ,WTHt 6604 612 I.IVfSf65',1517 .WT86t5410 1S
~'
.l,'·iT%G6·1%:J9 ,\',rnf.6640107 AV-3GG~42000 .\\ 1T8CG5•;1 ~J9 I
,',Vr%05 l05~,t ,\VTS666-l0J96 /1V-86664 1996 l,\VT8(G6f,1494 I
,',\1Tt\SG04D586 A\·T8666•1IJC-8d A\ITSi:GC-"1938 1,',Vl8606-lM86 I
,',Vl8~6t4'.J578 AVTSCGE40J70 A1rSC65-11970 LwT856f.41478 '
,~\.'T85CG"0:iSO J\','18666--10~61 :Av; 86fo419~}.4~·vT86661.1160 :
,,v-:-35554,:,551 ;\VT8656.J005) jr...v~a,oG641~'53 AVT8666~1451
PI\GE 4 OF 0 ED-FSA-09-D-001410045
Attachment Page
,\\.. ~c,,,::.:.9°.7 S~0- ~c~)o

-------·-·-·-----+---·-- -------
:,•,: ~:A,C-'9,'.~ 1,:,-.--s~,:,.:~1~2;
PAGE 5 OF 6 ':D-FSA·09·D-G014.'~0'15
SCHEDULE Continued
---- ----- ------------------~---~------------------j
SUPP~IESISERVICES QUANTITY I UNIT UNIT PRICE S AMOUNT S
1---- -----
Contracting Officer- Soo Kang, 202-377--3798,

soo.kang@eG gov
, Primary Con1rac11ngOfficer Representative: Tammy

Conr,elly_ 202.377.3298. rnmmy.connel y@ed.gov
Alterriate Contracting Officer Represer1tat1ve(sJ:

Patrice Wash1ng10r. (202) 377-3845,
Patrice.\/1/ashin,;iton@ed gov
Primary T echn,ca, Point of Contact· None
Alternate Technical Point of Contac'.(s)·

None
1 Contract ID Code i Page of ~a_g_eJ

__
_
' 1 3
2 AMENDMENT MODIFICATION NO 3. EFFECTIVE DATE 4 REOUISITION1PURCHASE REQ NO 5 PROJECT NO flf applicable)
0046 SEP 27 2012 EDOFSA-12-000984

------~-- --~~~~---1---------------~-~~-----
G ISSUED BY CUDE FSA-FS2 7 ADMINISTERED BY (If other than ,tern 6) CODE
Un·;ed States llepM~,e~t of Educat,cn
Fede a•, Studer! A·d.'M1ss1on S.Jpport Group
0 See Block 6
d30 F,·st St NE: - SJ1te 9F~
',f,Jasl11ogton
DC 2:;202
8 NAME AND AQl)Rl:SS Of CONTRACTOR (NO Street. Country, State and ZIP Code) I (X) 9A AMENDMENT OF SOLICITATION NO
lilGHER ECUCArlON ASSISTANCE AGENCY, PENNSYLVANIA DUNS 007368103
1200 NOfHH 7TH STREET
f--
Cage Code· 41UK7
~•NANCIAI M,'I.NAGEMENT 5TH FLOOR
HARRISBURG PA 171021444 98 IJAT:C □ -(SEEITEM11) - I
~--+-1"0A MODIFICA-flON OF CONTRAC-T1Q~

CC,-f"S'--:9-J-::,·
4
X
1OB DA TED (SEE ITEM 13)
CDDC: 00030774 FACILITY CODE JUN 17 2009

________ 11. TH_ISITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
D The above numbered sol1c,tat1on1samended as set torth ,n item 14 The hour and date specified for receipt o! offers D ,s extended, Dis not extended
07fers must acllnowledge ,ece1pt of this amendment pnor to tne hour and date specified 1nthe solicitation or as amended. by one of tho following methods·
(a) By completing items 8 and 15. and returning ___ copies of amendment (b) By acknowledging receipt of this amendment on each copy of the offer submitted:
or (c) By separate letter or telegram which 1,icludes a reference to the solic1tat1onand amendment numbers FAILURE DF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE Pl ACf:' DESIGNATED FOR THE RECEIPT OR OFFE:RS PRIOR TO THE HOUR ANO OATF SPECIFIED MAY RESULT IN Rf.JE:.CTION OF
YOUR 01 I H-1 If by virtue ofth1s amenamfmt your desire to change an offer already submitted. such change may be made by telegram or letter. provided each
tp_\h~ sol1citat1onand lh1s amendment, and 1sreceived prior to the opening hour and dale specrF,e_g
telegram or lette~_.'!7_a~eter_?..'!_£_E,
__ ____________ _
12 ACCOUNTING ANO APPROPRIATION DATA {If required) Mod11!cation Amount S442,670.00
See Schedule Modification Obligated Amount $442,670 00,
Check One A rHIS CHANG!: ORDER IS ISSUED PURSUANT TO (Specify authority) THE CHANGES SET FORTff IN ·1TE~i 14 ARE MAOf. IN l HE
CONTRACT OROE:R NO IN ITE:M 10A
X 52 212-4 Contract Terms And Conditions - Commercial Items ..Mar 2009) - TAILORED
B THE ABOVE NUMBERED CONTRIICTIORDER IS MODIFIED TO REFLECT THE AOMINIS1RAi IVC CHANGES (such as changes 111
paying I
office. appropnatmn date. etc) SET FORTH IN ITEM 14 PURSL,ANT TO THE AUTHORITY OF FAR 43 103(b) _J
----------- -- ·c_ THIS suPPLEK1E,\J~Ai 1\GREEMENT IS ENTERED INTO PURSUANT TO AiJTi~ORITY OF - - .. - - I
D. OTHER (Specify type of mod1ficat1onand authOf1ty)
E IMPORTJ::~T Contractor IX is 1ot_._[""_i=9_::1J~d to sign this docume1t and return copies to the issuing office
14 D!::SCRIP ti ON OF AMENDMENT/MODIFICATION ( 01gan1led by UCF sect,on headmgs, including solicitat1onlcontract subJect matter where feasible)
SEE PAGE 2 OF 3 FOR DESCRIPTION OF MODIFICATION
See Continuation Page
0 xc~:,t ;,s prov1d,,c h~r~,n a:I l~rms and '.end1t1onscl iho docu,ncnl rclc cnccct 111,tc,nOA or l,J,~ as horctofom_chansod rema,ns unchacqcco0a0'°c•c'c:u
0
, <occc e,o c oocC_________ _
0 0 0 0 0 0 0 0 0 0
15A NAME ANO TITL[ OF SIGNER {Type or print) i 16A NAME ANO TITLE OF CONTRACTING OFFICER (Type or pnnt)
: Soo Kang
, 202-377 -3798 soo kang@ed gov
i
15C DATE SIGNED' ' 168 UNITED STATES OfAii,1ERICA
Il
15B CONTRACTOR/O~FE:.ROR 16C bATE SIGNED
(b)(6)
1S1gnature of person authorized to s1g.11

l
~---~------~
(Signatur?ot Contracting OfficElr)
I SEP27,2012
'\\'\ -5411.11[-15~-S/1711 ~f.-\:,JD.-\RIJ FORM JO. I Re,. 10-/B)

Pr~1 :nu~ l:d111or1urlLb1bk
Continuation Page
The purpose of Modification 0046 to Contract Number ED-FSA-09-O-0014 is to incorporate the

requirements for Change Request Number 1827, Income-Driven Repayment Plans, in accordance with the
following attachments:
1. Attachment A - Business Operations Change Request Form [1 Page]

2. Attachment B - Income-Driven Repayment Plans - 2012 Requirements [33 Pages]
The requirements shall be implemented by the following dates:
1. For PAYE System Changes - November 6, 2012

2 For IBR/ICR-B Changes - December 31, 2012
The total contract value is increased by $442,670 from $196,913,258.10 to $197,355,928.10.
PAGE 2 OF 3 EO-rSA-D9-D-D0:4/0046
---------------------------------- ------
SCHEDULE Continued
------~----------------------~----------~-------j
IHMNO SUPPllES/SERVICES QUANTITY IJNIT UNIT PRICE S AMOIJNT S
I
-----i-
!
; Contracting Officer: Soo Kang. 202-377-3798.
soo Kang@ed.gov

Connelly 202 377.3298 tammy connelly@ed.gov
Alternate Contracting Officer Represontal1ve(s).

Patrice Washington (202) 377<l845,
Patr1ce.Wash1ngton@ed.gov
Primary Techn;cal Point of Contact: None
Alter:1ate Techrncal Point of Contact(s):

None
i (New Line Item)

'Requirements for CR #1827 - Income-Driven Repayment
Plans
0027 Per.nsylvarna Higher Educ3tIon Assistance Agency to 1.00 SE 442,670 00 442.670.00
1rip:ement Leg1slat1ve changes lo their servicing system
for l:lcome-Driven Repayment Plans.

0202A2012.B.2012.ENBOOOOO6CA 2521A AAJ.000.
0000.000000
S442,670.00
-'-- I .. I
PAGE 3 OF 3 ED-FSA-09-D-00'4/0046
Attachment A
Send all Change Request Forms to POCChangeReguest@ed.gov

Administrative Information
Service Area Validation for Submission Completed: ~ Defer: D ID: 1827 REVISED 9/12/2012
Requestor: Cynthia Battle Date Drafted: 7/23/2012
CR Title: Income-Driven Repayment Plsns Date Submitted: 8/8/12
Business Analyst: la Teata Jackson Anticipated Implementation Date:
11/1112
: FSA ServicefSystemfArea Impacted

C8]ACES Nelnet Platform 0 NSLDS 0 EAi
C8] Not-for-Profits (NFPs) 0 FPDM 0 PEPS/IPM
C8] Title IV Servicers (TIVAS) □ CPS 0 FMS
0 TPD 0 Part1cipat1onManagement 0 Security Architecture
0 DMCS/DMCS2 D EDExpress 0 SAIG
0 DLCS D eCampus-Based 0 AIMS
□ COD D Ancillary Services D Other: _____ _
D Notification Only: _______________ _

Implement attached requirements for income-driven repayment plans. including {revised requirements version 2.5
based on clarification meetings and Q&As received. Negotiated Ru!emaking_2012 Requirements 082812
QandAv2.5.x!sx)·
1 Income-Based Repayment (IBR)

2. Pay-As-You-Earn/Income-Contingent Repayment-A (PA YE/ICR-A)
3. Income-Contingent Repayment 3/lncome Contingent Repayment-B (ICR3/ICR-B)
Validate compliance with regulatory requirements for IBR.

Note. The IBR requirements as listed are based on current and proposed regulations. FSA expects serv1cers to be
compliant with current regulations As indicated in the attached spreadsheet, 1fthe servicer is compliant. the servicer will
provide procedures and/or business rules demonstrating compliance with the requirement. If the servicer is not compliant.
the servicer will provide statement of commitment confirming the date when the servicer will become compliant with the
requirement. Any "new·· requirements based on proposed regulations are indicated by "n/a." in the spreadsheet.
The possible contract requirements discussed in this document are based on proposed rules included in a Notice of
Proposed Rulemak1ng published by the Department of Education on July 17, 2012 The Department has invited public
comment on these proposed rules and will consider changes to the proposed rules based on any comments 11receives.
Therefore these requirements are preliminary and may be modified to be consistent with the final regulations that the
Department will publish after cons1derat1on of the public comments. The contractor will be required to comply with the
terms of the final regulations issued by tile Department and with the terms of the contract.
Reason for Change:

FSA anticipates the previously reference proposed regulations to become final 1n November 2012.
Additional Information (ALL OPERATIONAL IMPACTS MUST BE ASSESSED):
Does this change require a new network connection (Secure File Transfer Protocol is mandatory for all new
connections)?
No
1ST Anticipation:
None
Revised 3/21/2012
Page 1 of 1 ED-FSA-09-D-0014/0046
Attachment B
l11corne•Dr1ven Repayment Plcms - 2012 Requ11e111ents
lncome-Drove11 Repayment Plans• lOH Reqweme,m
,,.,.,'),,,
IBR Requ" em~11tsfor lrico11,e- Based Reea1"rient r· ar:

PAYE Heqtmemer1ts Im ~uy·A,·YOLJ·t,ll n
ICR Requirements fo, l"CG"'e Co11Unge11l
Repa·/'11HI
Ver,oon Control·
Dale Aucusl l, 2012 \/1 0
Dale ;u,:tast ll, 2012 - V2 0
Dale ;ugust /8, Nl2 VL ',
Page 1 ot 33 lcLJ+SA-09-LJ-001410046
Attachment B
lncorne-D,1v(m Rop;iyment Plans - 2012 Ruq1J1r(m10nts
IBf< Roq111rnmo<1!s
,,,.., ... ,,,..,, ,.,,, ...,_,
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1\IEMORANDCM FOR RECORD
TO: l·ILI·.
FROM: \:-,.;( ,11, S.\11rl I, C( l'-. rl(,\CT .'l'l•:Cl.\UST
SUBJECT: .\11:-.~I'\(; .\101)]1·1( .\'I 10'.\ l)(I.\-CT() CO'.\TltV:rl\l;:-.rn1-:1\ l]).1-·:-..\ 09 1)(1011
The puqio~t· o( this ;\fcmorandum to the Fik 1s to document the jump from l\{odtfical!on
00-16 to .\lodification U0-1-8in the Contract Folder The missing l\lodification U0-17w:1~ crroneouslv
created Ill the contract \Hiting srstem and is just a blank draft modification, which was never sent to
the scn·1n·1·. Therefore, there ts no S!'-30 for this modification for the contract fik.
! 1 P~g~ of Pages !
AMENDMENT OF SOUCITATION/MODIF!CATION OF CONTRACT 1 contrnctlDCode
'2 '
1 I 2 I
AMENDMENT MODIFICATION NO. 13.EFFECTIVE DATE 4 REQUISITION/PURCHASE REO. NO. 15.PROJECT NO. (1fapplicable)
!
0048 OCT 29, 2012 EOOFSA-13-000021
6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If other than item 6) CODE
Ur11ed States Department ot Education '
Federal Sh;deot Aid/M;ss,on Supp0rt Group See Block 6
Washington DC 20202
!
-8 NAME AND ADDRESS OF CONTRACTOR (NO, Street, Country. Slate and ZIP Code) 9A. AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY. PENNSYLVANIA DUNS: 007368103
{x)
~
1200 NORTH 7TH STREET CageCode:41UK7
I FINANCIAL MANAGEMENT 5TH FLOOR
HARRISBURG PA 171021444 SB. DATED (SEE ITEM 11)
'
' 10A. MODIFICATION OF CONTRACT/ORDER NO.
ED,fSA-09-0--0014
i X
I 108. DATED (SEE ITEM 13)

! 11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
0 The above numbered solicalat1onis amended as set forth in ,tern 14 The hour and dais specified for receipt of offers extended, Dis Dis
not extended.
Offers must acknowledge receipt of this amendment prior to the hour and date spec,fied ,n lhe solicitation or as amended, by one of the following methods:
(a) By completing items 8 and 15, and returning~~ copies of amendment: {bl By acknowledging receipt of (his amendment on each copy of the offer submitted:
or (c} By separate letter or telegram which indudes a reference to the soliatation and amendment numbers FAILURE OF YOUR ACKNOVVLEDGMENT TO BE
YOUR OFFER If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each
telenram or letter makes reference to the solicitation and this amendment. and is received nrior to the oneninn hour and date snecified.
12. ACCOUNTING AND APPROPRIATION DATA (If required) Modification Amount: .t>1,500,000.00
Mod1ficat1on Obligated Amount: $1,500,000.00
See Schedule
13. THIS ITEM ONLY APPUES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFlES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check One A. THIS CHANGE ORDER IS ISSUED PURSUANT TD: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO. IN ITEM 1OA.
office, approp1iation date. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b).
D. OTHER (Specify type of modification and au1honty)

X FUNDING ONLY
E. IMPORTANT: Contractor Ix is not, I rs required to sign this document and return copies to the issuing office.
The purpose of this Modification 0048 to Contract Number ED-FSA-09-D-0014 1sto provide funding for the Special Direct Loan Consolidation
(SDLC) Servicing. The total contract value is increased by $1,500.000 from $197,355,928.10 to $198.855,928.10.
- f~IIforce and cf!nct

J11t1tD
E>cep, as prov1dod horein all terms and cond1t1•ns ofth• document ce!erence<11n!em 9A or IOA as heretofore changed remains uncflanged and ,n
TITLE~?.E SIG~l;R .~T~?~-or~rint) 16A. NAME ANO TITLE OF CONTRACTING OFFICER jType or print)
! \ \ " ,)ll2-0,, D i
!
,y c-;J>, Soo Kang
202-377-3798 soo kang@ed gov
;1-15
\i?-"r~(~;JY\
.CONTFACT R(Q ,F.ROR
.\), (£c-h'~f . 1sc
\I (Y.'..Y-f-,ril_:r1·1x,,..-
DA, ....SIGNE ~
6B. DNITeo STATES OF AMERICA 1ec-:-DATE SIGNED
j
r)(6)
I ! ()(6)
0/1
OCT 29, 2012
(
1
(Signature of person authorirnd to sign) I ISinnature of Contrar.tfn11Officer)
- ""·
i'iSN 15.i0 .!.ll 1__ 80,il
Previous l:dit1on unusable - STANDARD FORM 30. (Rev. 10-83)
Presrnbed by GSA FAR (48 CFR) 53.243
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE $ llMOI.INT I
I'
Contracting Officer: Soo Kang, 202-377-3798, '
soo.kang@ed.gov


'Primary Technical Point of Contact: None

None
(New Line Item)

PHEAA Servicing SDLC
0028 Pennsylvania Higher Education Assistance Agency to 1.00 SE 1,500,000.00 1,500,000.00
service Special Dime! Loan Consolidations for Federal
Student Aid.
Accounting and Appropnat1on Data:

4253XNOYR.B.2013. EN B00000.A 16.2521 A.AAG.000.
i 0000.000000
$1,500,000.00
I
'
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'
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I
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'
PAGE 2 OF 2 ED-FSA·09-D-001410048
,
Contract 10 Code Paae or~
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT '
I ' ' I 4
12 AMCNDMENT MODIFICATION NO. 13.EFFECTIVE DATE 4 REQUISITION/PURCHASE REQ NO 5 PROJECT NO. 1if appl,cable)
0049 FEB 13, 2013 I
1 G.1ssurn BY CODE FSA-FS2 7. ADMINISTER[ □ BY (If o!her tnan item 5) COD[
' Un'1ed S:a1es Dcoa~mer.1 ~r Educat,on
Fcocral Student A,d/M ss,cn Supocn c,oup See Stock 6
83·J F1rs1St NE - Suite 91F3 I
Washington DC 20282
Angie Sm th 202-377-4016 ang,e s'll,th@oc sov
'------
8 NAM[ A\JO ADDRESS OF CONTRACTOR (NO, Street. Country, State and ZIP CodeJ 9A. AMENDMENT OF SOLICITATION NO
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVA'IIA DUNS 007368103
_l"I_J 'I
CageCode.41UK7
FINANCIAL MANAGEMENT 5TH FLOOR '-------------- -------- ;
HARRISElURG r'A171021444 98 DATED (SEE ITEM 11)
·----~---
MODIFICATION OF CONTRACT/ORDER
-·-··---·
NO.
X
'°' Ee-FSe-:i-0-00,i
1CIB. DATE:D {SEE ITICM 13)
CODI= 00030774 i FACILITY CODE JUN 17, 2009

·--·--!
D The above riumbered sol,c1tat1on Is amended as set forth In item 14 The hour and date specified for receipt of otters D Is ext,inded, Dis 101 extended
Diers must acknowledge receipt of this amendment prior to the hour and date specified in the solic1tat1on or as amended. by one of tile following methods
{a) By completing items 8 and 15. and returning ___ copies of amendment. (b) By acknowledging receipt of this amendment on e1ch copy of \lie 01tcr sc;bmIttcd:
or (c) By separate letter or telegram which includes a reference to the sol1c1lat1onand amenoment numbers. FAILURE OF YOUR ACl<:NmVLEDGMENT TO BE
YOUR OFFER. If by virtue ofth•s amendment your oesire to change an offer already submitted. such change may be made by !elegr.,m or letter. provided each
~~am or le_Qermakes reference to lhe solicitation and lhis amendment. and is received prior !o the opening hou~ a<1ddate spec1fic.1. i
12 ACCOUNTING ANO APPROPRIATION DATA (If required) Mod1hcatio.1 Amount. so.001
See Schedule
ModIfIcation Obligated Amount SO001
Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO· (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN l HE
CONTRACl ORDER NO. IN ITEM 1CIA.
B THE ABOVE NUMBERED CONTRACT/ORDER IS MCDIFIED TO REFLECT THE ADMINISTRATIVE CI-IANC,[S (such as c·1anges in paying
ot:ice. appropriation date. etc) SET FORTH IN ITEM 14, PURSUANT TO TH[ AUTHOF<ITY 0~ FAR 43.1 03(b).
C TH!$ SUPPLEMENTAL-AGREEMENi-1(,;"'ENTE-RED INTO 'PURSUANT TO Al, THO_<_ff_S~Q°F-·

-- ---- ------ -------j
II MUTUAL
X AGREEMENT BY BOTH PARTIES
D. OTHER (Specify type of rnod1ficat1on and authority)
E IMPORTANT. Contractor I Is not, Ix is required to sign this document and return copies to the issuing office.
14. DESCRIPTION O~ f,MENDMENTIMOCIFICA TION (Organized by UCF secIIon headings, including solirnatio111conlract subicct natter wliere feas1lile)
The purpose of Modification 0049 Is to revise Allocation Metrics #1 and #2 in Attachment A-4 Ongoing Allocation Meth1Jdology of the base IDIQ
coritract, as described 111Enclosure 1 of this modif1catIon See Enclosure 1
''
! All other terms and condItIons
,
remaIr unchanged.
1·,cep, as pro,·1do'1her~·n. all lenns and cond,t,ons o' the documeril re'erericed "' ,lem gr, or rnr,,as he,elofore cli.mged rerna,ns uriclldnge:I dlld ,., luli 'orue a 1d elfec,
1
15A Nfa.ME fa.NOTITLE OF SIGNER (Type or pr;nl) I 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
, Soo Kong
202.377.3793 soo.kang@ed gov
!
158. CONTRACTORIO~f'EROR 1sc. DATEcSIGNED" 1es.uN1Trn StAtEs OF AMERiCA -- [ -1ec DAE SIGNED------ -
:rW61
(S,gnalure of person authorized to s•gnJ
L ;!(/:;,(, ! ~l(b-1(-61-------~
(Signature of Contracting Offi(en
FEB :1,3'.2013
NS!\ 7540-0J.]52-8070 ST.-\:\D.-\RD FOR:\! 30. (Re\'. !0-83)

l'rcv,nu., 1-.dit,on \1!1'.LOi>b!~ Pn:scr;i-,~d by GSA rAR (•f8 CFR) 53.213
Attachment Page
ENCLOSURE 1
Effective with Quarter end perioC Sewember 30, 2012, replace descriptions fnr I/'. and ,;2
Jl1ocat1011factors in the lead secuon of Attachment A-4 as follows
"1. Percent of "ln-l{epa;1nent" Ponfol10 Dollars tha! go into drfoult - mc'Jsured J<,J
percentage of the Servin,'s Lurrent Federally !:eid ponlolio
<l. Petn'ntagc at Public Schools
b. Perce11t,1geell Private Schools
c. Pe~leniag,' at Proprie!dry School,
cl. Percentage Consolidc1t:011Loans"
"2 Pe1n'nt nt "ln-Rtapaymen!" l'Dn[olio borrnwer, that go mto dcf,1ult - measured JS il

percen(Jgc of 1he Servicr'> current Fed('rdlly held punfolio
b. Pe1cellldge <ilPnvdte SLl1oub
c. l'errent<1gr Jt Prnpricwry Slhooh
ci. PercentcJge Consol1danon Loun
2. Effrc<ive with Qua1m encl perioci September 30, 2012, rrrbce the Allocalion l\lc[ric !!l
incorporated in AttJchrncnt A-4 Ongoing AllocJtion /.lcthodology ot :he buse co11tr,1Ct
wilh the following li!ngu~ge elf ective with the Quarter encl period September JO, 2012;
"Allocation 'vl~tric ri 1 is to be measured quarttarly {calendar quarter>) for lmrrow~rs with nun-
conduit loans. Calculation = (Tot,ll Dollar Amount that are JGI ~ days <leiITlqucnt within l;ie
cu:wnt qu.irtpr) DIVJDf.D nY (Total Dollar Amount thdt ar~ ir1Repayment antl U to 350 days
dclmqucnt p!us the Total DollJr Amount thJt Jr~ 361 -- dJys only witl1111the currelll quarler). All
available quJrlerly ~cores in each cawgory (1 a, 1 b, 1 c, ld) will be averaged together on July l
ot each year tD cJkulate the FinJl Score for this JliotJtion metril.
Consol1dacion loans arc rcponed as a separate ca1ego1·yregardle~s of school (ype. The

Cun~olidalion loan Cdtegory will ahD include dDIIM Jmounls of SDLC/SCN loans.
Rehabilitated lo;m5 1~hich were temporarily ex( lu<lei.lfrom prior CJkubtion wdl now be
mciudcd m the ap?ropriate school or consolidauon category
1 Efternve with Qu::irm cm! pl'riod Sept~mbcr 30, 2012, repl~te the Allucalioll Metric /i2
incur µurvted i11Altdchrnerll A-4 Ongorng Alioc~uo11 rvkthodology of the b~sr contract
1,'itli th~ lollowi11g language dfeetive with the Quaner end period September 30, 2012,
"Allocal.ion i\,lctnc ;; 2 is lO be measured quannly (cdlenda1· quarters) for borro1,'CJS with ncn-
co11duit loa'.1'i.C1lcul~110n = (Tow] (r1111:tnt BnrrowPtS rhat ~rP 3(,1·• days delmqt1enr wnhin 1he
rnrrent quarter) DIV!DED BY (Total Count of Borro1,us that arc in Rcpaym~nt c1nciU to 3GU
day, delinquent plu, the Tmal Cocmt ot 8rnrnwer~ that arr 1Gl, days only within the current
quarter). ;\11 ovailable quanerly sco1es m each catcgoi)' (2a, 2b, 2c, 2d) will be ,wcrJged togc1lw1·
on July l ol each year rn calcJlate the l'inal Score for ihis a!loca(ioo metric.
PAGE 2 OF 4 EO-FSA·09-0-001418049
Attachment Page
Consolidation loans ~re r·eponeci a, a separdle category regardless of school type. 1 he

Co11sulida1ionloan cmegory \\'ill also include borrow('f', hc1vi11g
SDLC/SCN loans.
Rrhabilitaled loans which were temporarily excluded from pnor calculation will now be
'.ncludcd m tlic appropriate school or cDnsolidationcacegory.'
PAGE 3 OF 4 ED-FSA-09-0-0014/0049
---
I SCHEDULE Continued
' ITEM NO SUPPLIES/SERVICES OUMITITY UNIT UNIT PRICE S AMOUNT S
I
' '
I soo kang@ed.gov '
Primary Contracting Officer Representative: Tammy I

Conrielly, 202.377 3298.tammy.connelly@ed.gov

I
Palrice.Washinglon@ed.gov i
iPrimary Technical Point of Contact: None ''

i
j~~~~riate Technical Point of Contact(s}:
'
'
'i
PAGE 4 OF 4 EO-FSA-09-D-0014/0049

1 Contract ID Code I_1_:_ag"-~£3)~-- I
1 . 4 i
2 AMl'NGl, 1FNT MODIFICATION NO 3 F:FFFCTIVF: )ATE 4 REQUISITION/PURCHASE Rt:Q NO 5PROJEcT NC ,:,fapolicable)
0050 DEC 19 20',2
6. ISSUED BY CODE FSA·FS2 7 AIJMIN!SJ El~ED l:lY (:I other than item 6) CODE
'Jn11eds:~tes DepDrtmcn'. of Edccal,cn
Feceral S1ddert A1d•'Mission SJDtcort Group See Block 6
i:\30 ~irst St NC: - Su,to 91F3
'J'.las'11n:;itor.DC 20202
Ar,g.e Srr,ta C(•?-J77-401C ar,g1e sm1tC,:§cd gov
~[ AND ADDRESS OF CON-- l~AC i'Qr:((NCJ. Street. Country State and ZIP Code) (X){9A-Ai7ENDMENT OF SOLICITAT 1CN NO
rllGHER EDUCATION ASSl~rANCE AGC:NCY, PENNSYLVAN'A DUNS 007368103
! 72UUNOHIH7IH~TlffEf
· f-lN.'\NCli\L MN'11\GH,1f."T C""H FLOOR
Hf,?RISBlRG P1\ 171821'-44
CageCode.41UK7
r 96 DATED 1SEE ITF:~111)
I ·,oA, MODIFICATION CF CONTRr,CTIORCER NO

C~•-FSt
.. ;; ')-:'. I'.
X
108, DATED :sc[ 11E:M13)
CODE 00030774 FACILITY COCE JUN 17, 2009
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITAT!9~S, _______________ _,
D The a~ove numbernd sc,l1c1tal1on1samended as set forth 1nitem 14 The hour and date spec1iiea for receipt of offers D 1slc!Xlended, Dis 70\ extended
Offers must acknowledge receipt of tllis amendment prior to •he hour and date specified rn tt1e sol1crtat1onor as amen~ed, by one of !he foliow1ng meth~ds·
(~) By completing items 8 a--id 15, and rcturnrn,; __ copies or dmendment. (b) 3y acknowledging receipt of this amendmont on each copy o~ tile ot'.er submitted:
or ,:c1Gy separate letter or tel~g<d'l1 wl11ci',1nclud~s a reference le the sol,c1tatior and amenament numbers F;\ILURE Of YOU"< ACKNO'•/IJLEDGME!\T TO BE
RFCFIV[D AT 1111::PLACE DESIGN/1ED FOR TrE RECEIPT OK OHF:RS "RIOR TO THE HOUR AND DATE SPECIFiEO MAY RESULT ,N RC:JECTION OF
YOUR Of-I LIS If by virtue of :i"is ariendment your desire tc change an offer already submitted, such cha~ge rnay be niade by telegram or le:ter, prJv1ded each
j.
teie, ram or_l~.ttcrmal1es rotnrcnce io the sol1,~1tat1on ano th,s amendment, and 1s rece,ve_?J?r:!9f_~(!_the
open.ng hour and dcitQspoc,t,,:,d _
12 ,\CCOUN ! ING AND /-1r'PRO"RIA TION OAT,\ (If reqJ1rod) Mod1f1cat1on Amount· $0 00,
See Schedule Modification Obligated Amount SO 00 1
Ct10ck One A. THIS CHANGE ORDER IS ISSUED PURSUANT TO. (Specify authority) THE CHANG<::SSET FOR~H IN ITEM 14 ARE MA:JE IN THE
CONTRACT ORDER NO IN ITEM 10A !
I
G Tl I[ AG:J\IE f\'L'MBERED CONTRACT10RDEr\ IS MODl[IC:D TO Rc:f:..ECT THE ADMINISTRATIVE CHANGES (suet, as change~ 1~pay.ng
office approp,iat1on cla:e, etcj SET FORTH IN I fE:M 14, l'URSUAN": I UTHE AUTHORITY OF FAR 43.103(bi
C "i·H1$ $LJi;i-;·LEME'NTAI AGREEWCNT IS ENT'.c:REDl'HO "URSUANT TO AUTHORITY 01:-:----··---·
X MUTUAL AGREEMENT BETWEEN BOTH PARTIES
D OTHi:::k ,;SpEic1fytype of f11od1ficat1on

ar,d authority I
E IMPORTANT Contractor I 1s not, .X 1s req1.med to sign this document and retL.rn _ copies to the 1s%in~~'="="='--------
i 14 DESCl~ll'T ION OF AMEND\1EN~/MODIFICA TION {Organized by UCF section headings, 1nclud,ngsol1c1lat1on/co"traclsub1ec:tmal!lclrwhere feasible}
: SEE PAGE 2 OF 4 FOR DESCRIPTION OF MODIFICAT!ON .
. Se<c Co,il1nuati:;rn Page
15A NM-,F: AND TITLE OF S-GNER (Typ" ur p11n1) 1'3A NAME AND l lTLE OF CONTRACTING OFF'CER (Type or pri·1'.)
isoo Kang
j202-377•3798 soo kang@ed gov
15Ei-CON fRACTOR1nf-:r:ERfR 15C DATE slGNFDf.fos.UNIT[D STATES OF AMt:RIC/\ 16C. DAfE SIGNED ---
b)(6)
l(b)(6)
DEC 20 2·J12
(Signature of person auti,011,ed to sign)

(Signatui"' ofCor,tra~~rig fficer)
'sSi\ /S.!0-01-152•8070 ST.-\c'<DARD FOR.\! 30. (Re, J(]-83)
P1n1ous hJition unu,.obk l're,crib~d by GSA F ·\R (-t8 Cf'R'1 53.143
Continuation Page
Continued from BlocK 14 ...
The purpose of this Modification 0050 to Contract Number ED-FSA-09-D-0014 is to hereby replace the
pricing table found in Section 8.13.N 3. of the contract with the revised pricing table found in the following
Attachment Page [page 3 of 4 of this Modification 0050], in order to incorporate the per borrower per month
cost for TEACH Grant Servcing into the contract.
Grant Servicing and Loan Servicing are two separate chargeable activities
PAGE 2 OF 4 ED-F-SA-09-'.J-0014/0050
At1achment Page
Thi: Uovcrnment sh:ill set and rn:magc th<: common pricing, inc!uding til'r
structun:. as ,how in the tc1blebelow.
JJJ(J().()(10
3,000.1)01 UI' \
1,600.IJ(J(J s
Ul' I
lfot rower~ 31-90 Dav~ J)d in( u<:nt N--'A \
e-_____ 91-15(: D~ ·s Deline ucnt
_cllcn_cnc<"'>\1~1s 1';.·_-\ s
Borrower~ 151-270 DJ_\5 Del ill" u~nl Ni,\ s
lfotTOII et·', 270 I Da, > D~lin( u,:nt i\ 'A N ,\ s
Bommer, ill rl:,\( l l ljr:rnt Status \'/A N.·.-\ s
Out :-·carpricing ~lwll follow the rnetho<lulugy,as desnibed in the krn1s ,,rScction
13 13 \' ul the conlrncl.
PAGE 3 OF 4 ED-FSA-0'.J-D-UU14/005:l
SCHEDULE Continued
IT~M NO, SUPPLIES/SERVICES QUANTITY ! UNIT UNIT PRICE 0 A~OUNT I
Comracting Officer· Soo Kang, 202-377-3798.

soo.kang@ed.gov
P i111aryCor.tract:ng Officer RepresentatIvo: Tammy

0
Con10·Iy, 282.377.3298, tamrr.yconnelly@ed.gov
Alternate Cont acting Officer Represer1talive(s;·

0
Patrice Washington. (202) 377-3845

Patnce. VVash 1ng1on@cd.gov
Primary Technical Point of Contac;: None
Aiter-1ate Techn,cal Point of Contact(s):

Nono
PAGc' 4 OF 4 F[J-FSA-09-D-0004/00SJ
1 Contract ID Code ~_Fy--9..'c

of Pa es
1 12
TAMi:NDMENl MODIFICATION NO 3. EFFECT!VE DATE 4 REOUISITION/P0IKHASE:. REQ NO ~ PROJECT NO, (1fappl,cablOJ
0051 FEB11,2013
6 ISSUfD BY coo:: FSA-FS2 7 AOMINISTERE'O BY \If other thar ilem G) CODE
U11:cd S:a:Gs C,cpa'1me111 of Educat,oc.
Fccc·a Student A1clM1ss1onSuopa~ Gcocp See Block 6
830 C,rs: St :-,J( - Scite 91 F3
Wash1ng10nDC 20202
re~==----------------- ----------- --
8 NN,-1E AND ADDRESS CF CONTRACTOR (NO., Street, Country, State and ZIP Code) ~ME'°ME'"T QC SOUCITATION NO
HIGHER EDUCATIO'\J ASSISTANCE AGENCY. PE'NNSYLVANIA DUNS· 007368103
:200 NORTH 7TH STREET Cage Code: 41UK7
FINANCIN .. MANAGEMfNT 5TH FLOOR ---i
HARRISBURG PA 171021444 I :98~DATED (SEE' ITEM 11)
10A MODIFICATION or CONTRACT/ORDER NO
x' '-~~·~~~~-~-----~-
108 DATED (SEE ITEM" 3)
ED·FS,\-09-J. ,J,J14
CODE OOG3C77
4 FACILITY CODE JUN 17, 2009
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF§9 0L0IC0IT
0 AcT
0 I00 0N0S~---------
D The above numbered sol,cItatIon Is amended as set forth in item ',4. The hour and date spec1nedfor receipt of offers D Is extended. Dis not extended
Offers must acknowledge receipt of this amer.dment pr;or to lhe hm.:r and date specified in the sol1c1tat1on
or as amended, by one of the following r'le:hods.
{a) By completing items 8 and 15, and returning __ copies of amendment. (bl By acknowledging receipt of this amendment on each copy of the offer submitted.
or (c) By separate letter or telegrGrn .vhich includes a reference to 1he sol1citat1onand amendment numbers FAILURE OF YOUR ACKNOVVLEOGMENTTO BE
RECEIVED AT lHE P\.ACC DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFEi'l: If by virtue of this amendment your desire to change an offer already submitted, such chanse rray be made by telegram or !etler, provided each
tele ram or letter rnaAes reference \o (lie sol1c1tal1onand !his amendment and Is received rCorto :he D er.in hour and dates ecii1ed
12 ACCOUNT'NG /\ND APPROPRIATION DATA {If required\ ModIFIcatIcn Amount. $0.00
Modifica\ion Obligated Amount: $0 00,
See Schedule
! 13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14
I
Check One A THIS CHANGE ORDER IS 1ssurn PURSUANT TO. (Specify autt,onty) fHECHANGES S[T FORTH IN ITE~114 AR"EMADE IN THE
CONTRACT 01,0ER NO. IN :rcM 101\
B. THE ABOVE fJUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE A0f,1INISTRA TIVE CHANGES (such as changes ,n paying
office. appropriation dale, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43103\b)
--------t 0c- 017H"1"s~suPPi."Et.i°ENTAL

AGRl:::.EMl::Nf IS ENTERED INTO PURSUANT TO AUTHORITY OF
';
X Mutual Agreement Betvveen the Parties
'I D 01HER (Specify type ofn°odifica1rnn an□ authority)

!
, __ J___~-~--------------------)
E. IMPORTANT Contractor r
Is no'.. Ix Is required to sign this document and return copies to the issuing office __ _J
14 i'IMOOlf'IC/\TION (Organized by UCF section nead,ngs, inclu(!1ngscl1citationlcor.tract subJect rnatler where feasible)
cJESCi~I!-'! ION OF AME::N.JMC:N ---- · II
T'le pu,pose of this Mod1ficat1on OC51 to Contract Number ED-FSA-09-0-0014 Is to incorporate tre Attached Small Business Subcortracting Plan
111\0the contract 1
'
All other terms and condi:Ions re--r1aInunchanged i
E,ceol as prov,deD here,n, all Wms and cor•d111oosor lho d0ccment referenced n ,lem 9A or_1DA, as herelufore cr.ar,ged, rerra,ns c,ncha~ued anC n full lcrce and dfeci
15A NAMl ANIJ Till[ 0~ SIGN EH (Type or pr.nt) 16A. :-IAMEAND TITLE OF CONTRACTING OFFICER (Type or pcint)
; Angie Smith
1202-377-4016 angie.sm th@ed.gov
i
I 15B. CONTHAC IOR/Or, 00
ck 0°R~-------
0 0
·- ' ·,5c DATE SIGNEJ 1GG.JNITEO STATES OF AMERICA 16C. DATE SIGNED --1
I
---------~L , i, -rb)(6) '
i2/1//13 ll
FEB12 2013
j"(b-)(_6_)
(Signature oi persor, autnonzed '.o sign) I (S1gna'.ureot Contrac-.ing Off;cer) I
's~N 75--!0-01-152.so~n ~-1.-\!\!JARD FOR\1.30. (Re,. 10-83)
Prnious i:J1t101Junusabk Pre,crib~J b, GS:\ F.,\R ('18 CTR) 5) H"l
Attachment Page
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PAGE 3 OF 12 ED-FSA-09-lJ--001-1/0051
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C. ·;,,o·. 1Ce_,J,-,_.,,,
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0
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.. _-, ,·.:l'l.'U O:'f,1 I: l~ !' :CO
PAG~ 9 Of' 12 EO-FSA-09-0-01) 1 4:'0C-51
Attachment Page
'Du·rtodI··-·
~1·10 \1.c:ll,c,,.~) \,,so .)olC'i,,:\ '.:9,2:11:, ':\amo· - , ·- .. , LJ,,e

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''-'"'lance h{'""'Y
PAGE 10 OF 12 ED-FSA-09-D-0014/0057
Attachment Page
Cm.TRACTfNG OFFJGR
T{?ED NAJ.{E: s'-"' .1~<.i·v'i

/b1(6) I
RE'/JEWEDBY:
SIG!\"ATLJRE:
T I
Offi=
Cont.ractiug
r
DATE:
PAGE 11 OF 12 ED-FSA-09-D-C-014.10051
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY I UNIT UNIT PRICE S AMOU~T S I
I
!
' I
Contracting Officer- Angie Smith, 202-377-401 6, ' 'I
ang1e.sm1th@ed gov
'
Primary Comracting Officer Representative Tammy
Connelly 202.377 3298, tammy.connelly@ed.gov
A1ternato Contracting Officer Representative(s):

Pat·Ice WashIng:on, (202) 377-3845.
PatricG.\/Vasl1,ngton@ed gov
Primary Technica: Point of Contact: None
Alternate Technical Point o'. Contact(s)·

None
PAGE 12 0~ 12 ED-FSA-09-D-Q014/0051
1 Contract ID Code PaeofPaes

2
2 AMENDME'H \10DIFICATION NO. 3. EFFECTIVE DATE 4 REQUISI flQN/PURCH/1SE REO NO. 5. PROJECT NO. f1fapplicable)
0052 JAN 01, 2D13

6. ISSUED BY CODE FSA-FS2 7 ADMINISTERED BY (If otnerthan item 6) COD[
Un,ted Stales :JeoMrrent or Education
.0e:Jeral Student Aid/Mission SuppDrt G•cup See Block 6
830 First St NE· Suite 91F3
'•Nash,nglon DC ~0202
Angie S'11ith 202-377 -401 6 angIe smIth:1l)cd ;ov
-- -
8 NAMC: ANO ADDRESS OF CONTRACTOR (NO., Street, Country. State and ZIP {od-81 9A. AMENDMENT OF SOLICIHIT!ON NO---~~
HIGHER EDUCATION ASSISTANCE AGENCY, PENNSYLVANIA DUNS· 007368103 ~
M
1200 NORTH 7TH STREET Cage Code· 4',UK7
i
' HARRISBURG PA 171021444 9G. DATED 1SEEiTEM 11/
I
-----
10A MODIFICATION OF CONTRACTIOROE:.R NO. I
ED-rSA-09-D-:lil14
X '
10B DATED (SEE ITEM 131
0 . " THIS ITE:_~.OJ:l!::._Y

APPLIES TO AMENDMENTS OF SOLICITATIONS
The above numbered sol,c,talron ,s amended as set forth In ,tern 14 The hour and date specified f~r rnce,pl of offers
----
D
Is extended, D,s not extended .
Offers must acknow Iedge receipt of this amendment prior to the hour ar,d dale spec,fied in the sal1citat1on or as amended. by one of the following methods:
(a/ By completing ,terns 8 and 15, and returning ___ copies of amendment, (b) Gy acknowledging receipt o' th,s amendment on each copy of the offer subrrntted:
or (c) By separate letter or telegram which includes a relerence to \he solIcItatIon and arr.endment nurrbors ~Al LURE OF YOUR ACKNO\IVLEDm/ENT TO BE
R[C[IVED AT THE PLACE DESIGNA fEO FOR THE RECEIPT OR :JFFERS PRIOR TO THE HOcJR AND DATC: SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER If Dy virtue ofth,s ame11dmenl your desire to change an offer already submitted, such cl1ange may be made by telegram or letter. provided each
te!egrarn or letter makes reference to t:ie soi;c,tat,on and th,s arn~ndment and ,s received prior to the opening hour and date spec,liud
12. ACCOUNTING AND APPROPRIATIO,\J DATA \If required) Modificat:on Amount SC00 !
I
Modification Obligated Amoc1nt S0.00
See Schedule
13, THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTSIOROERS. IT MODIFIES THE CONTRACT/OROER NO. AS OESCRIBEO IN ITEM 14, ,
Check One A. THS CHANGE ORDER IS ISSUED PURSUANT TO (Specify authority) THE CHANGES SET FORTH IN l~EM 14 ARE MADE IN THE
CONTRACT ORDER NO IN ITEM 10A.
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGFS {such as changes in paying I
office, appropr;aI1on date, etc) SET FORTH IN ITEM 14. PURSUANT TO THE AUTHORITY OF FAR 43 103(b) _______ '
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANTfo AUTHORITY OF·
--------t=~===~~-~~~~-~~~~~-----~~------------ ____ ____j

I D OTHER {Specify type of mod1f,ca\1011and authority) 1
E IMPORTANT Contractor is not, Ix is required to sign this document and retur1 copies to the IssuIng office.
14. DESCRIPTION Oi' AMENDMENTIMODlf"ICA TION (Organrzcd by UCF section headings, including sol1c1tat1onlcon(ract subject rna'.ter where feasible)
The purpose of this Mod1ficat1on 0052 to Contract Number EO-FSA-09-D-0014 is to extend the period of performance •'or the Oefau:t Aversion Pilot
Program. The new period of performance will be from January 1. 2012 through December 31 2013
FEB28, 2013
(Signature oi person authorried to s·gn) (Signature of Contracting Officer)

\'SN 7540-0l-152-811711 SL\:'iDARI) FOR',130. (Rn. l0-83)
Pr~,iou, F.d1Lim,unu,a':,k f'r~s~r,bed b:, G'IA FAR (-18 CFRi 53 ~-13
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT ' UNIT PRICE S AMOUNT $ I
'
Contracting Officer: Angie Smith, 202-377-4016,
ang ie .sm 1th@ed.gov
Primary Contracting OfIcer Representative: Tammy

Connelly, 202.377 3298, tammy.conneily@ed.gov
Ai,ernate Contract;ng Officer Representative{s):

i Patrice VVashIngton, (202) 377-3845,
Patrice Washington@ed.gov
'
PrIn1ary Technical Point of Contact: None
Alternate Technical Point of Contact(s).

None
I
'
'
'
'
i
PAGE 2 OF 2 ED-FSA-09-0-0014/0052
FSA09D0014-0053
f_'"~:L:_-_·
AM EN DMENT OF SOI_",c_1T_A_T_1_o_N_1_M_o_o~1F_1_c_A_T_1o_N_o~F-C_o_N=T_R_A_c_T~~I
_' _'_°'_,,,_ac_"_'_'_''_'====''~--"-"'~
12 AMEND!.',Ei:T 1-.'.0D~ICA~'ON 'Jo. 3 !:CFECl;V': DAT!: 4, REO:JISITIONli'URC!-oASEREQ. NO. E PROJECT NC (I' app·,:aolo)
'' 0053 FEB 2B, 2013
7 /\DM1t;IS"ERED1i"Y'1"11-o",c-,-,-,,--,~-,-,,-,-,,-,--,-~,-o-c"E
________ _
f 6. ISSUED 8Y C:Jl)I:. f'SA·FS2
, •Jnced State, Depan:rnct er tducal'M
h~or:,I SicCor.t;u;.·,,11,s,c,1ZopoM Groce See Block G
HJC Fir-;: Si N~. Sul\O ~1•:)
'Nmi'ir,,i:or DC :iC2C2
f,ngie ~rr.ilti2ff!<'17 .407 Garc,;, ,~1.•0€,,, u<>,·
; ~Ai,;': NSD A0DRE'SS Or' CONTRACTOR (NO. Slreel. Counte;, Sta"i,iiM ZIP Cu~tJ 9A A~1~'JDM'::N7 OF SOLtCl-:-A-IOfl NO.
{x)
GH'.'::\ EDUC/\";10.'l t\SSISlANC!: Al3ENCY, PlcNNSYLVANli\ DU:,./S, 007350103
~
00 N0Rl'll7fd S";fl::":C:T
N/l!SCIAL /.'1\NIIGE':-1.(F.t-.T 5Tf\ FLcor,
1-1'<RISEL:RCl-'ll '7".C-21~~~
Cag~ Coce ~1UKi
r~--
: I
9B DAT'COO
(SE£ IT2M '.1)
~Ot,. f,lODlf'!C:,Tlor-· (JI' CONTRACTICRDERr-:o,

I X ·. rn-Fs:-w-u-0J1<
! , 1C8,DATED(SEEtTEITT3°)--------~
! FAc1•_;,ycoo,;: ----i I JUN 17,2C09
~~--------------11. THIS.ITEM ONLY APPLIES TO At,1ENDMENTSOF SOLICITJ\TIONS
D lhe a~ovc r,umheced sollci\aliari :s an,ended as sc,tfortn ,n itcrr V,, Th~ hourLJnd t!o!e spocired for mceip\ of oife·s
O is extBr.ded. Dis ·101exler.dcd.
O!f~rs mus1 ad-mc·u!~C.ge ,ece1pl ofh,; an1endme~: prier I~ 11,e hcLr a:iJ cc.te s;,ccilcd ·n 1he soll:lta!lon O" ~s ;;merl'J~'d. by Ont cf tllij [oilo•;,sngmelhO<Js·
(~) By cornpic!,ng ,tcmo8 Jnd 15, Jn<! 1oturn,ng___ ~opios ot arrendmcn'.: (b) B,' ac·,r.o,•/~cglrg ret:aip! 0ft:1is ~mcr,tJnl(mtor, eacr CDf.\'~, meoffer subm tte:J;
er(~) l3y sep;rale le'.1erer '.eiegram ,·.-hid·.incluUes a rnfer~ncc \o :he ool1t;i\a\ionand smendrrenl m:'llbcr3 f"AILURE OF YOUR ,~CK(ICl'ILEDGMEN~ TO 81:
r,
P.ECEiVEO A'7 TrlC: f' ...AC:F.DESIG/1:ATEDFOi< THE RECt:'P~ OR OFFERS PR!O!l TO THE HOUR \J'.) DAI"- SPECIFIED MAY RrnuLT IN REJECTION OF
VCJ'JROFFF.«. If b·r virtue of th:s amcndmem yo~r oesir~ to cha<igu011alfor alreaJy sut" llted, such ch-Ong~may be made by telegram or letter prov,ded eacn
_£,ls_g,a,n m lel:er '!.'_aSes~~!crone:, \J the solicitation aric 1h15efl'_enclr",cnl,anj i~ received onor :o lite opernng t,our und d.~le specifieC. ___ -----~
I 1:i ACCOi.JNTl~JGAf.:D N'l''<Oi"RIATION l)A l A :1freqLJlred) Modiflcat:on Amount $·4,631,667 76
S<oeSchedule Mc;d:ficat-on Obli~ated Arrou;-t $·4 5:,1,607 .76
13. THIS ITEM ONLY f\PPLIES TO ,\10DIFICATION OF CONTRACTS!QRDERS, IT MOlJIFIES THE CONTRACT/ORDER NO, AS DESCRIBED IN ITEM 14.
THC:G!IANCES SC FOR-r't !fl TEM 1~ f,RE t,1A1:'f;lf::;"ff,E
A Tl-II:; CliANG:' ORDER .S I.SSUED PUP.SUA'IT l'O. ,'.Spoc'ry1>u111or1!yJ
~
CCNT~ACT CRDU~ t-.0 IN ITE:M 1ur,
~x----- [l 7-iE ABC VIC ~U\H'!Fht=:C cc\j7~/\(Tr(:'<D~R IS liOi:lf(~D ":'O Ht::FLECTTHE hDMit-.lSmA TtVE CHAI\GES i~·.1cl1J~ ci'Jng~s ,1 pay1c,J I
olTk~. ~~poi;"a11on ds!r. ott) SET FOP.""HI~ ITEI.I 14 PUilS'Jt,N7 TO THC AUTfcOrmv CF FA.'<i3 103ib).
i
c. ·n11sSL.rPLEMEN.i'i'",,-, 0,c=e•,"s"M"e"a"c-."s"c"s"T"c"s"E"D"l"""'"o"c"a~,
"r"o",";u=n°•0=,
0 ,0 0",",,c,"- 0
«"Y"o=,-,
-------- - ------·-------·---
O: 1-[:q (Specify type of modifi~JI ,_r, and ~u!horil'/)
E 11''.f'Ck I ANT· Coiwoc'.or I is not. IX is rec~ired to sign '.il s (i,;,cumer: and re\ur~ .. J co;:,ie5 to tiia 1s,~ing office
14, ~,F.SCRIPTl()N Of' A\1HJl)1,'I, \JT,iil0D'FICAT 10N (Or!]~r:.led ;,. ucF-;~·i:1,-Jn
ne,1ding~.,n~i"d-~g $Q 11Dto:,~n!c~ntrocla;Jtjec: 11a11~,WIME feasible)
SC::EPASC:: 2 o~ ~ FOR DfSCi<lf'l ION '.JC MODIFICJ\TIO~J
1-1.-\I.;__'--,t ,;,-
fEB·:W, 2013
I\SN ':5•10-')!· 1 '."·807(1 S'I ,\.\' ll:\ll.ll FOlt~l 3LJ,(Rc1'. I 0·~.l)

f'r,cvinll_<Ecl11•)1\ u".\JS~l,k l'r~.scr,lx,:1 ~l' C,S,\ l'A'.Z \~~ LTR; i3 2-IJ
A\tochmor,t P~go
Th~ purp:,s~ cf this mcdif1cati~n ,~ to ce-othgJt? development funds 'n t~~ tot~I amou~; of $1,lSS.01:1
and f,,rc, fw $p~c;a! [);rect Consol:da1ion ~oan prot,am :n tr.e ~mou~l of $3/36,675 76. The combine,'.
tot~I to be de-obdc;J\ed by tl'I; 'lldincat,~n wo:1'd tie s,,,631,637.76 Funes wocl~ ~" ,k-'-'bligotcd
f1on1:re bliowi ·~ Ii% 'term"' iis;ed o~low:
S7C,012UU
$250,0C-O.00
ssoo,ooom
$375,CCO00
lir·c item J4 ;:y:z SOCLI'
I SCHEDULEContinued ~-· 7
I ,TC'd;,0
-l-----···-·----1
UWTPRlCC $ i
··· ·
O\"•JU"1
·--------1
! '
I
CMlrncling o:fcei· S::,o Km•~. 202-377 -3198,
soo ~ang@ed.gov
f'rimery Crint,ac1ing Of:'ice· Representa:lve: Tnmrn)'

Con•1tally. 202.377.3298, tammy.connclly@ed gov
';~t':,'.n11t e
,cc~tr~:11 orr,;:,r
~,g ~ ve(s):
Rcpr-:-:entut1
, a,.,ce \l'.nstdng.c ,, (202, ~, 7-384;i,
Petr:co. 'Nash ingm11@et.1.gov
I
Pri11,ary Techn•co! Point of Conloc',: t1one
I Mor,'o!O 7echr1cal P;;>;n!of Conluc'.(s):

None
(Ct1ongod L·no Iler,)

0,i Roq.HJS!NJr:iner FSAO:JCOGO.
Ac<1:.t1~1:1f'l<m
00·,2 FwmJ'ng for Ti! e IV S,irv'cing Se 479 968.or::I 479,988.80
Accourt'nG «nu A~prcprim:on Da'.a:

C20?J\2U11 B.2011.ENBOJ000.0CA.LS21;\,Af1J.000 .
.0000.ocoooo
i$479,91l8.0Q
'IBOC:2521/\
(C!1ar.ged Line ilcm)
0015 FundCr,9lor Title II/ ~€rvic;ng 5ysterci enhoncer,,cnls. 1.00 SE D.00 0.00
A1.coc1rr'ng m,tJ App·o~rialion clat:::·

0202A2(J12.:J 7012,[NSOJ(WO.GC/\ 25211'..AA.J.00-J.
0000.ooacoo
SOOG
{Ch;,r,,J,·d L.ne lterr-,1
0'.)20 Pcrr.syivar,ic, H'gner EOJcn:,011Ass,~tan~e l'qency !o '.OC SE 0.00 0.00
n·,ak"' enrancerl\.'nh e~d system cl-.angos rcquosled b\'
FSA.
1,\ccount,na Jlld A~promi81,on Data:

1
'J~02/\2012 3.2•)1 2 EN60U000.6CA.252~A.MJ.OQO
,I JOOJ OCOOQC
'S0.D0
(U1,ir1g~d Linc ltcni)
Spcc•al c:i1rectLonn :::onsci:da1ioci ProcessqJ
Acou!sHion ::!an Hequesl Numbc, FSA0U'.J0(;C- Title IV

."-Cdltic~al Sc:':icers (TIVAS) ?OS i.C
0024 lo~,ov1Cc lcmjl~g 1cr Pcn~syi•,ar.l~ r,grer Educa1ion 1.COISE 2.063,324,24 2.063.32A.24
Ass1srnnce Agecicy to precesc, Special Direct Lo~n
Consolida::01J
.
!
l\r:courling and Appror,rivt:cr. ~,l\ci: I

"-253XN0YR.B.2.J12.~N~:JOOCO /115 2521A AI\G.0:JO. _I
0000.0GOOGO
s2.CG3,324.24 1•
1
:(C~ange:J L:"no1:er,o.)
1.001 SE o CO- 0 00
00?6 ] ?ennsytva~i~ Hi~!1'alrEducatic:, A~sisl~nce r,goncy '.o
sy_"_'_"_·----C----CI____ ______ J__ __
, crcv'de ew,;mce'r:~nls tn :heir servicing
l ----·--------------- .. .. . ..
SCHEDULE Continued
CL·ANTl!Y
..;_·---~-··--
____ --·---~-·-· . ··------ - --· -
jAccou,~ting .;nd Appropri~Con Data:

AAJ.000.
D202A2G12.B.2012.l:NBC·0000.6CA.2521A
80CO.OOCOQO
$0.00
0 9 01 0
_o_F_c~o_N_T_R_A~C~T=~i~C~o~"~'"-'~"__'1~'-,L1~_'
I AMENDME~N~T~O~F~S~O~L~IC_1T_A_T_I_O~N-/_M~O~D~1F_1c_A_T~l~ON_, 2;_'_-
_c_"'_"===--.Lf_~
:2 AM[NDMENT MODIFICATION NO 13.EFFECTIVE DATE 4. REQUISI !ION/PURCHASE R[Q NO I,5 PROJECT NO (11appl1cable,1 !
0854 MAY30,2013
----------
6 ISSUE:D BY
U•11teuSt2tes Jepanrnent of Et.Jcat en
-----~~~-~=~~-l---~~~~------c"--~~--------
COD[ FSA-FS2 7 A.OMINISTERED [W 111other 1nan ,tern 6) CODE
F~o;erdl $1ud~:il A1dlM1ss1aa $.JppM Group See Block 6
830 f-irst Si NE Suite 9F3
'.\13Sh1ng10n[)[ 2C202
Ar1g,e Sm,tn 202-3 77 -40' 5 aog,G srr,thr§cd qov
- ,-----'
8 N/l.ME AND ADDRl::SS OF CON I RACTOR 1_NO.,Street, Country, Stale and ZIP Code I 9A. AMENDMENT OF SOLICITATION r:.f()'-
HIGHER EDUCATION ASSISTAN::E AGENCY. PENNSYLVANIA DUNS 007368103 1<) '
~ !
1200NORrh 7IH SrREET Cage Code 41UK7
FINANCIAL MANAGEMENT 5TH FLOCR
HARRISBURG PA 1-i1021444
C--------__j
9B. DAHClJ 1Sff ITEM 11)
~~~~~~I
10C.. MODIFICATION OF CONTRACT/ORDE':R NO.
EO-f'S~-G9-D-00'
4
X
.".fciB OAlED {SEE ITEM 131 !
1
CODE 00030774 ! FACILITY CODE JUN17.2009
C------------------1 01~•c"c"~"=EM_(_)_!'!_L_r_~PPLIES
TO AMENDMENTS OF SOLICITATIONS
D lhe above numbered sol1c1ta;1on 1sa1nended as se\ forth ,n ,tern 14 Tho Mur Jnd date specified for receipt of offers 1sextendeo. Dnot exte'lded D,s
OIiers must acknowledge noce,p1c,f this amendment prior to the hour and date specified m the sol1c1tat,onor as ariended. by one of the follov1tng methods.
,,a) By cornp:e1111g
,terns 8 and 15. and retur111ng___ copies of amendment, (b) By acknowledging receipt of (his amendment on each copy of [he offer submitted,
or (c\ By separate letter or telegram which includes a reference to the sol1c1tationand a,nendrnent numbers FAILURE OF YOUR ACKNO\IVLEDGMf::NT TO BE
RECEIVED Al 1 HE l'LACE DESl~NAED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION or
I
YOUR CF"ER If by virtue of th,s nmendrnent your desire to change an offer already submitted such change may be made by telegram or lct1er, provided eJch
telegram or letter make5 rofomncc to the, sol,c,tation and this arnend,n_ic.!:1.l.:..
1? ACCOUNTING AND APPROPRIATION DATA (II mqu,red)
and is rece,veo pnor lo the opemng riour and dJtc sp~.c.!_fied
Modification Amount S0.00,
i
--~--~--~~1·
! See Schedule Mod1f1cat1on Obligated Amount SO 00!
Check One A THIS CHANGE: 01-Sl)U-SIS ISSUCD f-'URSUANf fO (Specify authority) THC: CfMNGES SET FORTlt !N 'TEM 14 ARE MADE INTHE
CUNIRAC'I UkLJC:k NO 1:, ITEM 10A.
B THE ABOV[' NUMflE'RED CONTRACT10RDEr, IS MODIFIED TO REFLECT Tl IE ADMINISTRA TIV[ CHANGES {such as changes m paying
off,rn, appropriation dale. clc) SET FORTH IN ITEM 14. PURSUANT TO Tl-IE AUTl+ORIT'Y OF FAR 43 103\b).
C. THIS SUPPLEMC:NTAL AGREEMENT IS ENTEf~ED INTO PURSUANT TO AUTHORITY OF.
X Mutua> Agreement Between the Parties
D OTHER 1Sp,3cilytype of modification and authocity)
--~-- IMPORT_~NT·_ Contractor I ,snot, rx

1s required to sign this docume11t and return copies to the issuing office.
! 14 DESCRIPTION OF AMEND~IENT/1/0Dl"IC/\ TION !Organized by UCF section headings, 1nclud1ngsolic1tat1on/contractswbJeCImailer where f;:,as,ble)
! SEE PAGE 2 OF 5 FOR MODIFICATION DESCRiPTION
See Cont111uat1on Page
Cxcepl as provided herein, ~,I 1crms ana cond1t1ans o1 the documen1 reterenced ,n ,tera W\ ar IOA, as t1eretoloce ctia·,,_~~--'~~~
rlS urchanged and 111lllll torce and elfec,
15A t-,;AMEAND TITLE OF SICNER,(Type or print: 16A NN,1E AND TITLE OF CONTRACTING OFFICER (Type or pnnt)
Angie Smith
202-377-4016 ang,e srnith@ed gov
' ! '
~F~,e~,~,o~N~TRACTOR-(0-,-,c:ROR 15C DATE SIGNt:d i6&UI-_JITED STATES OF AMERICt, 16C DATE SIGNED
____ J
,---
rb)(6) ! l(b)(6)
·MAY 30 2013
(Signature of person authorized to s1gnl (Signature o1Contracting Officer) 1

:,..:sN 75--10-lll-15:?.-8070 STM\D.-\IU) FORM 30. (Rn. 10-1-:3)
l'rcv1ous Ednion unusable l'r~_mibed by CiSA h\R (48 UR) 53.243
Continuation Page
The purpose of this modification is to add 272 additional Personal Identity Verification (PIV) Tokens as
Government Furnished Property (GFP), in accordance with the terms and conditions of the contract.
The serial numbers of the tokens being added, per this Modification 0054, are listed in Attachment 1 to
Enclosure 1.
PAGE? OF 5 C:D-FS/\-09-D-0014:'0054
Attachment Page
Enc]()~urc
Date: 05.'?0-'2.llLi
FSA Con1raning Officer: ,\ngk Smith
Contrnl't ~umber: ED-[-::,1\-09-0-001~
Suhjcct: 1,lll\'Crnlllent l·urnishc:J l'l'llpeny i_liFPJ
The V er·iS1gn'.R.ID f'l'11kction l'cr,onal l<lc•n;i1;\' (ri Iication (l'I\') \o.-:cns 11c:·c 1s~ueJ to lhe
11roonty mJtMgcr I\Jr ;,~,iJnmcnt t,l all personnel who supporl Lil~Jh-.11c·-rns:ntinncJ cu11tuct.
s~e ,-\llCKlrniem I t,,r s,-r;al nurnl1cr<;of the token\ 1~,ucJ w lhc cnntrnctor.
PAGE :J OF 5 ED->'S/\-09-D-0014-'0:54
Attachment Page
Attachn1ent 1
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PAGF 4 oc: ~ [D-tSA-09-0-001,1/0054
------ ------
SCHEDULE Continued
ITEM NO SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE 'i
Contracting Officer: Angie Smith, 202-377-4016.

angrc.smith@ed gov
Prnnary Contracting Officer Represenr.alrve: Tammy

Connelly, 202.377.3298. tammy.connelly@od.gov
Alternate Contracting Officer Reoresentat11•e:s):

:Lynn Smith, 202-377-3577. lynn sm1th@ed.gov
'Patrice Wac,h1:1gton, (202) 377-3845,
Patrice. 'N c1shrngton@ec.gov
Primary Te:::hnrcal Point of Contact: None
Alternate Techn1ca1 Point of Contact(s):

None
I
---- ---------
__[ __ ,
____
PACE b OF t, EC-FS/\-09-D-C014/:JCl5~
I 1 Contract ID Code :- Pa_ge_o_f

fO~_ge~
I I 1 ' 2
2 AMEl'iDMC:NT MODll"ICAIION NO 3 EFFECTI\/E DATF. 4 Rl'QJISITION/PURCHASF: RF:O NO 5 PROJECl NO (If applicable)
0055 JUN 24. 2013
6. ISSUED GY CODC: FSA-FS2 7. ADMINISTERED BY 111other tl1an ,tern 6) CODE
•Jn.tad States DepMrrer\ o' Eo'ucat,or
:'oaBral StJden, f:1d1M1ss:on Supvon 2roup See Block 6
EJO Hrs, St N!c • Suite 9'F3
'·1\•ash1rgtcn DC ?020/
Angie Sm:1~ 202-377-4016 ~ng:e sm1th@ed gcv
- --.. ·~·-- ., "

; NM'il:C ANIJ AODRl.SS OF CO\JTRACTOR (NO S:reet, Coun·ry, State and ZIP Code) 9A AM[NDM[NT OF SOLICITATION NO
II H'GHER EDUCATION /1SSIs·c,\~CE AGENCY, i't:CNNSYLVANIA DUNS 007368103 1,1
1200 NORTI I 7Tf- STREC:T
--
Cage Code 41UK7 !
' FINA'JCIAL MANAGC:ME:NT 5TH FLOOR
; ------ ----------
HARRISBURG f'A 171021fl.44 ; 9B DATED (SEE ITEM 11I
'' - i
' <OA rvlODIFICATl:JN OF CONTRAC":/ORDER NO I
! ~=·-CSA-1>!-C·-lm'
X I
10B. OATCD (St£ ITE),113)
' CODE 0003077 4 I FACILITY CODE

I JUN17,2009 !
'
11. THI$ ITEM ONLY APPLIES TO AM~ND_M~NTS OF SOLICITATIONS ----1
D The above riumbored sol1c1lht1onIs amended as set forth in item 14 Tl,e hour and date Spl!c1fied for rece;pl of offers Is extended. Dis not exlend~d. I D
Ofers must acknowledge receipt of this amendment prior to tr.e hour and dale specified in the sol1citat1onor as amended, ty ono of the follow,rig methods:
(d) By completing ,terns 8 and 15, and returmng ____ copies of amendment; (b) By acknowledging receipt of tl•is ;imondmerit on each copy of the offer submitted·
or (~) By separate letter 01teleg,a~l v1l11cl1 includes a reference to the sol1c1tationand amendment numbers FAl LURE OF YOUR ACKNOVVLEDGMFNT TO BE
RI:CEIVED i\T 7 HC l'LACF '.:JFS'G!\ATE8 FOR THE RECEIPT OR OFFERS PRIOR TO THF HOUR AND DATE SPC:CIFIED MAY RE:.SULTIN REJECTION OF
YOUR Ol-Tl:::l'I If by virtue ofth1s amendment your des,re to c'lange an offer already submitted, such ~hange ma/ be made by telegram or letter, provided each
klugram or letter makes refere_r:1s:~.l() the s0I,c,tat,on and this amendme~t. and Is received pnor to '.he oponmg hour and date spec1f1ed.
12 ACCOUNTING f,NU Af-'f-'ROf-'!<IA! ION DATA (If required; ModIfIcatIon Amount $- f,000 000 00
See Schedule ModIfIcat1on Obligated Amount $-1,000 .000 00
13 THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS IT MODIFIES THE CONTRACT/ORDER NO AS DESCRIBED IN ITEM 14
Check One A. THIS CHANGE ORDER IS ISSUED PURSUANT TO (Specify au'.honty) THE CH/1NGES SET FORTH IN 11t:M 14 ARE \-IADE IN THE
CONTRACT OROC'R NO. :N ITEM 1 0/\
a Tri£ t,BOvl: NUMlJ[RE:D CONTRACT/ORDER IS M00IrIED TO RCFUC:CTTl I[ AOMIN ISTRi\.TIV[ CI-IANGES (such as changes ,n pay,ng I
office, ;ippropnat,on date. etc) SE:T FORTH IN ITEM 14, r'URSIJANfTO THE AUTHORITY OF FAR 43 103(b)
C THIS SUPPLEMENTAL AGREEMFNT IS ENTEC\ED INTO PURSUANT-Ti5AU'1'i--i6RITY or. ---------- - ·7

C----x----+-Mutual Agreement Bet,veen :he Parties -------------------- I
.L~-~:::~=(Spec1fy type of mod1fical1on and autt1oi,tyJ· -------------·---------- . ___
E. IMPORTANT Contractor I- Is not rx"is requ;red to sign this oocument and return.. r::ooIes :o the IssuIng office
11
~
114. DE:SCRIP"';"IONOF AMENrn.lENTIMODIFICATION (Organized by UCF section head,ngs includ,ng solic1tation/co11tr~d.c,,cbcJeccclcmcaCllcecc1c,l_ae_1_e_fo_a_s_lb-le_J
___
The purpose of this mod1ficat1cn is to de-obligate excess funds, in the amount of $1,000.000, from Contract Number ED-FSA-09-D-0014, Line Item
C028 The total contract 1alue decre;ises
1
by S1,000,000.00 from S194,224.240 34 to $193,224,240 34
Ali 0P1er terms and conditions ·emain unci-anged.
F,cerl as µ,oa,JeU t,ereir, a:I :~rrns and ,ond1t,011sof II·,edocumenl ,elerenced i•, 1'ern 9A or \OA, as lwrcto!ored1anged re,ra,ns u11C/'d11qeJ,ir·d ,n lull lcrce ac.d cfkct
15A N.t,ME AND TITL.[ OF Sl3'\JER !Type or prir,1) , 16A NAMF ANn T'TLE OF CONTRACTING OFFICER (Typs>or prr11:)
.,~,,-\,.-';,·\'\/I <~--) c_·_,;., , ,-, IAngi,aSm,th
76C
1
I\ I v•~-•.-r,I •\.1\,, '"~-\.- .._y--' ~>::i --"- 202-377-4016 angie srn1th@ed gov
i ,.--)~~, (""",
!\.i\··-r'-··~-l:'
~~-- ) .•
f""': "-'.)\
,~¾,_,_ • .,._, E -
>(-[;P~:,
'' l,/
... -·•--\;J•r1.
L\_ \ , --1: 1{l'J""\,·J\1j~
I " ':±'' •• ·----
1 150 CO:-.JTRACTORyOi'FE,'lOi:r° \ '-~ =-'---'----t· !SC oiTE s,GNED rns'QNi,rn S,AFS OF AMERICA DATE SIGN CD
b)(6)
' (b)(6)
'I JUN 25 2013 '
I •j ~,'<". u Li.,,,
I '
I
I (S,gnaiure of person autronzod to 51911)
(Signature of Con!,;ict,n~ Oillcer) '
-- -
N:>\J n-10-IJl-1)2-80,0
.,
S 1.-\\:IHRD 'FOR',I 30. (Re,. 10-10)
l'rc·,·w,,;; !Cdi11onunusable l'r~:«;ribd by (,S,\ ]·,\R 1-rn CFRI 53.?.-13
SCHEDULE Continued
ITEM NO, SUPPLIES/SERVICES QUANTITY UNIT U~IT PRICE S I\MOU~T I
Contracting Officer: Angie Smith, 202-377-4016,

ang1e.smith@ed.gov
Primary Con'.racti1g Officer Representative· Tammy

Connelly, 202.377.3298. tarnmy.connelly@ed.gov
Alternate Contracting Off:cer Representalive(s):

ILym Sm1tl1, 202-377-3577, lynn.sm1th@ed.gov
Patrice Wc1sh1ngton,(202) 377-3845,
Patrice Wash1ngton@ed gov
A1:ernate Technical Point of Contact(s):

None
(Changed Line Item)

0028 De-obligc1t on of funds (S1 ,000,000) 1.00 SE 500,000.C0\ 500,000.0C

4253XNO YR.B.2013. EN B00000.A 16.2521 A.MG. 000 _
0000.000000
S500.000.00
I
P/\GC: 2 OF 2 ED-FS/\-09-D-0014i0055
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT I 1. Contract IDCode Paoeo!P~~

I I 1 I , I
2. AMENDMENT MODIFICATION NO. 13.EFFECTIVE DATE 4. REQUISITIOWPURCHASE REC. NO. 5. PROJECT NO. (if ap,ilicahlo)
. 6. ISSUED BY
0056
1 Ur.;1~dS!~:osOop.,rtmen! of Education CODE
AUG 01, 2013
FSA-FS2 7. ADMINISTERED BY (If other than Item 6)
I CODE
Fe<jeralS:udon1AiOIM1ssion Suppa~Gmup See Block 6
830 First St NE. Suito 91F3
Washincton DC 20202
$. NAME AND ADDRESS OF CONTRACTOR (NO., Streel. Country, Slate and ZIP Code) 9A AMENDMENT OF SOLICITATION NO.
I
HIGHEREDUCATIONASSISTANCEAGENCY,PENNSYLVANIADUNS: 007368103 (X)
1200 NORTH 7TH STREET ~ I
Cage Code: 41UK7 '
i
10A. MODIFICATlON OF CONTRACT/ORDER NO.

ED-FSA.ll9-0-COH
X
I FACILITY CODE
'
CODE 00030774 JUN 17, 2009
I
D The above numbered sol:cilallon is amended as set forth in item 14.The hour and date specified for receipt of offers D is ex Iended, Dis no\ eitended
Offers must acknowledge receipt of this amendment prior to !he hour and date specir.ed in the soli::ilolion or as amended, by one of !he following methods:
(a} By compleling i1ems 8 and 15, and returning __ ccp;es of amendment; (b) Sy acknowledging receipt of this amendment on each copy of the offer ~ubmitted:
or (c) By Mparate letter or tolcgrom which includes a rererence to the solicitalion and arr.endment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATEO FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR OFFER If by virtuElor this amer.dment your desire to change an offer already submilled. such chanse may be made by telegram or letter. provided each
tel=mm or le1te1makes reference 10 the solicitolicn ond this amendment. and Is received prior to \he onenlnn hour <mdda\e snecified.
'
1 12. ACCOUN rlNG ANO APPROPRIATION DATA (If required) Mod1ficalton Amount. S0.00
'
I See Schedule Modification Obligated Amount: S0.00
13, THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MOD!FIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
B. THE ABOVE NUMBERED CONTR-6.CT/OROERIS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changm; In paying
office, appropriolian dale. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
D. OTHER (Spncify typn of modi~catian and ault,orily)

X Mutual Agreement of both parties
I E. IMPORTANT: Contractor l is not, fx is required to sign !his document and return __ 1

__ copies to the issuing office.
! 14. Di::SCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF secLion headings, inc:ud,ng solicllalion/ccntracl 5ubjocl matterwhere feasible)
1
a. The purpose of this modification is to establish a contract term that memorialtzes a procedure for issuing a summary modification of change
requests \hat link the change requests lo the modirication that provides funding for lhe change request.
b. This contract includes a line item or multiple line i1ems that .•.See Continuation Page
16C. DATE SIGNED

; b)(6) --f
/ I AUG D'(, 2013
!Slgnatue of person authorized lo sign)

(Signature or Contraclin Iccr)
NSN 75-10-01-1.52-l!OiO J S1A'-'.D.-\RD FOR:\! 30. (Re,·. J0-83)
l'rcvinlls E,lition unu~~hk Prescribe(\ b;• GSA FAR (4X CFR) 53.]-13
Continuation Page
provide funding for change requests. The parties to this contract agree that, in addition to any modifications
that add line items to fund change requests, additional summary modifications will be issued to identify
all change requests that link back, by change request number, to the modification that provided funds for
those change requests. These modifications confer no additional rights to the contractor other than those
identified in change request supplemental documentation between the Contracting Officer and servicer.
c. The total value of the contract remains unchanged.
d. All other terms and conditions remain unchanged.
PAGE 2 OF 3 ED·FSA•09·D·0014/0056
SCHEDULE Continued
ITEr.lllO. SU??llESISERVICES QVMITin' \)1111 VNITPRICE$ AMOU~T $
Contracting Officer: Sao Kang, 202-377-3798,

soo.kang@ed.gov

Alternate Contracting Officer Representative{s):

Lynn Smith, 202-377-3577, lynn.smilh@ed.gov
Patrice.Washing1on@ed.gov

None
'
I
'
I I
PAGE 3 OF 3 ED·FSA·09·D-C014/0056
1 Contract ID Code Page -f Page,

_A_M_E_N_'□_M_E_N_T_o_F_s_o_L_1c_1_TA_T_1_o_N_1M_o_o_1F_1_c_A_T_1o_N_o_F_c_o_N_T_R_A_c_T_~~---~~~L 1 'I 8- ,
2 Mlll::NlJMC:Ni MOIJ:f-lCArlON \JU 3 l::FFl::CrlVI:' lJAl I:' 4 Rl::QUISI rI0NiPU"l.CHASE REQ. NO 5 PROJECT NO 11!appl1caDle)
J057 AUG t5. 2013

6 ISSUED BY ------- 0c0o0o0c~~F'S"A=-"F"S"2-----t=,~A'DMINIST
0e=e
0e=c~,,,=,
0,r=,
0rh=,=,
0rh=,=,=,,=,=m=c"1-~c
0o=o=c------------i
Un.,ed Sla:es De,Jrtm~n, cf C:duc;,110~
F~oeral Stucont A,d,Miss on ScpFc~ Gr~up See Block 6
83U First St ti~ Su,te 97F3
'NdStllr'.',S'.0)JC 20282
Ans c s-,1n202-377-4016 ,.ng,c srr1t1@edgcv
8 I\AM:..CAND ADDRESS OF CO\JTRACTOR (NO. Stceet, Cour-try, Slate and Zif' Code/ (x) I 9A AMENCMENT OF souc1iAT10"-J NO.
r--<tGHEREDUCAT!0N ASSISTANCt A3fl\·CY, PENNSYLVANIA DUNS 007368103
120~ \J0R-:-II7TH STR~ET
FINANCIAL fi!\N,~GEMENT 5TH FL0O'<
Cage Code 41UK7 7
,"iARRISBURG ;:,A 171021444 9B DATED(Si::l::lil::M',1)
MODIFICATION OF CONTRACT/OR□ER-Nff-i
C)'S' O·JG'J'J"4
X
10B D/\.TEC (SEE ITEM 13)
------ - - -
::;oc+:00030774 1
. F/1CILITY CODE JUN 17, 2009
_ TO AMENDMENTS OF SOLICITATl,0 0N0S~--

_!1-.:__Tlj~SITEM _0.!:!~'l'._-~PP_L~ES
D The above numbered sol1citatio11is amended as set forth In item 14 The hour and dale specified for rocc,Ipt of offers D Is exteiade•J, O1s not extended.
Olfers must acknowledgG receipt of this amendment pr,or to the hour and date spec,fied ,n !he sol1c1tat1or,or as drnenued. by one of tile fol,ow1ng methods
(a) By cornpldr,g ,terns s drld 15, and ,eturncng ___ copies of amendment. (b) Ry acknowledging receipt of th,s amendment on each copy of the offer submitted,
anc amenoment numbers. FAIi.URE OF YOUR ACKN0 1/-JLEDGMl:::NI l 0 Bl::
or (c) 8y scµ~rate lutter or telegram which includes a reference 10 the sol1c1tat1011
R[CE:IVf:D AT TH[ PLAC[ 0[SIGNATED FOR THE RECEIPT OR OFFERS PRIOR :O lHI::: HOUR /\NO 0ATE SPECIFIED MAY RESULT IN REJECTION OF
YOUR :JFf'l::R If tiy vIr1:ie of th,s amename~t your desire to change an offer already submitted, such change r'lay be :nade by telegr;irr or letter, prov,ded each
\elegrarn or letter ma<es re'erecce to thP.sol1c1tat1onand this amendment, and IS_'.~.'ce_iv_e"~
prior 1()the oper1111g
hour and dale specified
12 /1CC0UNTING AND APPR0F'RIATI0N D,~TA (If requ1.cedj ModifIcat1o'l Amount· SO00
Mod1f1ca11on
O\:il1gatedAmount· $0 001
See Sci"'edule
c-=c=,-,-,-,-o~,,e-~A~.
-,"HIS CHANGE o·RCER lS 1SSLJEOl'URSUAN;i""'i'ff (Specify aUt~ority) THC: CHANGES SEl FORTH IN ITFM 14 ARF MADE IN TrE
CONTRACT ORDER \JO l~J ITFM 10/l.
cl -r"rlt ABuv1::
NIJl,1Bl::Rl::D C0NTH1\C i"i0RDER IS MOCIFIED TO REFL[CT T~ ADMl.'llSTRAf"1VECrlANGES (such-a-;; Cri"aflQesin-payirlQ__,
offce. appropna:Ion date. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b)
C THIS SUPPLEMENT;\L ACREEMENT IS Et\'TERED INTO PURSUANT TO AUTHORITY OF
X Mutual Agreement Bet,veen the Parties
D a-HER ISpec1fy type oCmod11icatlon and authority)
,i_
=E===l1
0C0P=O=Rc--TcA=N=Tcc~C=c=oct=t=a=ccfo
1t=!-=c'=.s='='°='=·='X~
0,sc=ce=q='="="=d~lo~s
1ig00~th='=s=c=o=c='='m~e
1o=f=a
1c=d~ee=t=c-m~~~~~opi_~~-'.~h~ ~~u_1i:1._i~ff'.~----~~----
, 4 DESCRIPTI0~ OF AMENDME·\JT:N,0JIF ICA TION (Organ.zed by UCF section headings, including so:1c1tat1on/comractsubIect matter where foas,blo)
; SEE PAGE 2 OF 8 FOR DESCRIPTION OF MODIFICATION
See Continuation Page
bceµI 1ler" 9f, or 1M as lwrctofore changed ,ema,os unclla11Jed ana 111

as µruv,dee riere,,,. all ,~r:,is and c0rid1l1onsof the docurneo: ,erercnced 111 fell !ore€ and e'fecl
16A. NAME ANC TITLE OF CONTRACTING OFFICER iType 0" pnnt)
1Soo Kang
, 202-377 -3798 soo kang@ec gov
76C DATE SIGNEO
AUG 20. 2073
iS1gnalurn of Contracting OltiC8r) I'

\J','\ -5 lli-Ul-l 'i'.'-80-il
l',-~,:iou, hliti,.111 umcsabk
Continuation Page
The purpose of this Modification 0057 to Contract Number ED-FSA-09-O-0014 is as follows:
1. To incorporate the Loan Consolidation Requirements into Section C (Statement of Objectives) of

the base IDI0 contract, including the 5-Year Option Period. [see Attachment A - Loan Consolidation
Requirements]
2. lo incorporate the common pricing structure for Loan Consolidation into Section B.13.N.3 of the base
1010 Contract, including the 5-Year Option Period. [see Attachment B - Loan Consolidation Common
Pricing]
3. To incorporate by reference, FAR Clause 52.216-11 Cost Contract- No Fee, which applies only to the
one-time development costs, not-to-exceed S1,200,000.
PAGE 2 OF 8 [0-FSA-09-D-0014/08:>7
Attachment Page
Attachment A - Loon Consolidotion Requirement,
New Direct Loan ConsolidationProcess Requirements

HequitomenU Seouiromoat Comments Cornoli•nt Yo, o, Nol Val1dat1on Artifact
70001 OU COO ,hall mutl,ly ,1,de,,tloa ,s,go•i to mommodate a,w DHC<tloan
cc=~~--+'c''c'c'c""c'c'~'on f!.:°'"" See t,tt,ichon,onn l & '
/0004 00 St<,Oentloam io, mall allow bo""''°'' lo O((O>StOe rev.,ed cunsal,dat,on
hc•,oSc•C(U''SC "' ,, "'',•,,I""'"•'' ,1,.1 Le ,.. ,.,oe,latec >'· Lh lcac

"""""""", ,,c,, dH e,· ".SI D.S 'he Salo 'ccc ,we·i•ly bo,oc u,ed 1o,
ler,.,, Ll, sl a b-.' ,·iocl ',c-1to ,cc f '" ,.i, ""'"""°'' lt da;e, Ioar
,-,,,u, ,•a,, ,,,,,_, c"''"'"" n;.- \eeAnadH""'" 1-l CS 24ondl\
70003.0U St,rientluanl go, shall moc,t','/le,mge th,, CPN S<h'"" used by the
5-eml 01tect (oa,ol,dat,on p,O<e», as nmled, to aliow lo,"'"'"'""°"
uf ,ontpletcd oppl"ation and ptam"'"'' note JalJ lot con,ol,dat,on loan
to ,pptap,M1'' TIVASa, dete<rr.med bv o,11r,but,oa og;, tu be spe<1lied D,
,>IA, \,,, Mta<lweat l
170023.00 Student(oass ~c, shall dete,,rnne ;f the omowe, ,s atle,npMg to
lccn,ol.date any undetl1·mg loam that are held b\' OMCS ,ad ,r so, ,efe, \!,e
bonowe, ,o the le~•<Y le p,ocrn at LoanCon,ol;da,,on,od ~"" Ith"
alternate pa:O ap~roach w,11be m place ,nt,I such""" as OM(!' ,s bmught
I
I"' nn the aew LCa,occs;es) ;cc A,t,chmc,•" 1. 2, n acd 1"
!1006£.0D ;NILOI shall p,o,ode ,eal-:,me d<ta feed to l:uOeatlnaas io, fo, the
""'po,e of p,e-"opula1'ns :>ae Loan Consolodat,oo a,pl"at;on Seo
l~,1a,',c,e":l
7JOCGCS
c·sbu·sc,>,e": dote ,o,'n ;:,tu; c,"e ( oc,, o:o•.,s , , rc1d\· c:,o<rnd ,,
I "'" feed) ''"' ,:-,,""'" "" "' ic-a,1 , cro,e:,1,1•,c !,oleo• a,
, ,I,,.,.,:,• I) '"" A:tachnent\ 19, l4, '5
70129,QO TIW,$ snail l,vc,a,c "' mod,fy thci, ,ystem to be able to a«cpt loan
con;ol,daMn appl,c,_t,on, hort ltudcntloao,.go, lee Attachm,·ct 1, 2, 14
'"''°"
Sho"/e,ocedure,
, 7Ul2~ 01
" \,oll ,w_•,t '""'~, g lco" coa,o:,a,L,o" ,,p ,c,,.o »and'"'"'"""
n,,,,, "'°''"•''''"' I,'" \""'""'Loans co,·,,,, ,o, fl'SISA G lee
Alta<lnne"" 14 ,s
170:37,00
'.~~~:~Proced ures/ ,a
pie ,cports/ »mplo
J
I
'"'"""'""""'
70138 QO TIVAS,n,,, "'°"",ash""' ofts to 00111,e, ,u,h "'""" loan holdrn,
!O~s, or✓,CS, and YHS ;,,,. ao,,,chmeo;; & ,,
"'""
<ho<s/P mceriu•e;/ sa m I
ole repott,I ,ample
rocoo<1liat100, '
70. JS 01 ;•,.,II e ,c,.,•,, ,vC,,'cLVC,for o·,.•," 1,,,,, ,,cl,,,,·•'" ,!,s•_, b,to ,, on-
·..,e occe,•, c-,aa,I a,•c."o, "'"I Seo Attoc'1ment '.O
S ,all IP ,--ale LVU•c.\ '.•, for GAs ,,cc k·,Ll"<c ,; o·, "'°,ccu, e
L-------1- ,,,,,,,,1,ocd/u, "'''·' S<·eAttochm,,,, 1U
701Jo C-3 s,,,., 1;,,,,e,,H,· L',,[,. ,,_,,:, ·o· }~'C.,a;I (, ,t,,Cc·e ,,., c, , ,,, access,,-
L-------J-c'""'"C'
;u Ill 0-1
c'C'C'C'C"C'c'"C'
c'C''~"''°C'c'C"C0C"'C'C'
il•,all ,;,,,,e,,,:e
__________
_•,u/ec','C•, fo, ,••I, ;,,H' C,S'.t C 'I•' l\ ;,,, I·,, ac<css, _,
-+--------+-------->-------J
"' Sec As:",h""'' 10
',I, ,11,;-•ae, "' c,, c•·r ,,,, ,·,ci,
fc, ,·,me 'o, -, , n dm and d"" "·"'
j
t,•,·nc, 1,,., ,J, , , ss ,, ,.,,, ti/" ,. ,, >cc·At,, '"'"'"''' 12, , □, "'" 21
'
I, 01),] JG
,'~~~~--·~-''''''""''·
,,.,,1 ;en ,.>t,p<,
,,, ,,,, ~"'''/C,
c,f•" ,cs,1 ic, G·" JC,d c,s,r o
""' ,,, A\\<rn,lC"ll 12. IO, ,n; 21

,ie J,. c, I,"
; 7Qlll 11 "oll ,,,,,,,o:c o,,,. off,.., ,,,,,,·, lo, J,.,c'. a,•U, "'''"" C'/ O"· c,e
,ccc» c ,,,,,, ,c,j•o· o•,a,I<,•e Attachment> 12, l•J, """ 21
,hall,,'"" C "' c.-f '""' l'CSL fo, Hf-j ooc d """ ,., b·; U" I,,'
~-----~-c'c"c"c'c'"e-ra.,d, ,·d:'ur ""I ,ce AttocCment5 "· >J. '"" '1
PAGE 3 OF 8 ED-FS,\-J9-D 0014/0057
Attachmem Page
Attachment A- Loan Consolidation Requirements
I New Direct Loan ConsolidationProcessRequirements I

Comment, Con,pl;anl • Yes or Nol v,1;da1,on Artifact
J'i13B 1; \I·, I """°" ,,,1,, ,s,c r,",..C I "'""'lc-stscco,·,od t·o,~ :,n,,,,,,, loas
"O Je,1 SN' A1t.1eCcion:< 1} ,o, and 21
' ; , , '""'"',cc""> o!I, fc, ,.,,_,,e:o,-a 0
0 d ··,,, •'"''-''°'"'"' ,,, F le
~~-~---+--'c'c"c'c'"c"'' lo;,~, SecAt:ad,me"l
n
10 . .)o ls 1·,.,1 e<'"""J",• :·,·1 01'1'0, ~,\• ''" 'c,c'l.,l•O Ir •;,ce -,leac,J ,u·,,, · <e
,,,, I ,1u,c,o;o ,:,z,y-c·h b jM, S ,, .., >u-<l,01,• ,,u,ce F,:e O"l'.Isoba"I

tc C',1\ See At:a,hm,nt l/
Soa, C°'""'" pa,· o!rc b ·II·'."" ,,,cha,e 1,,,,0,-,, C, e"" s,:l, < t to
j
f',;S SooAttacCs,entn
70167 00 TIVAS w,11ieneratethe fl(AL em,cam Report eo, appl"•'"ons that have
Oooled ,,·hm· ~[AL loans 1,0,e po,d off. See M:ac '"'C,11 l l \.ample H'Al
Sample Repac~
___ -----c"c'c""c'c'c'"c'c""c'~------------------+--
1 ·oe •,,,.,,,m st p "''-' c "''' c,_,,,•.•,o S,",·l·c ,.0,,,1,1,
·;,,.,w l~ample sy<tom
;,1,,c,"i;, ,,- ·,e;;, •,cc, st ,nacth •, '<"""
u,•,,,·,·'''"''"'" "' Bal,,,c,n~
t ,11"'"' ,,g •e•'•> (t ,• T ,,,,\ U, >va,:so ,ea•.,. IL,,, .co·> P,o_e',m ul all Recon«l,at,o"
1
""·'"'' ,u 1 ;c o,,J cocc•,s•c•d1,,,-n ·he ,10:,; Icon '°"'0 d,·o,s
,.,la"''·"
"'" d•· " ,,,o, "'' sec, ,- ,e "'PO" , ,. I ,,c ,Jc• , "d
I""°"
0
,: •
See Attachm.,,:1 8 s,,,,,1., Se,;,ce, \,·,te r, Sa:.""''" Se,c,oed"l'o"

""'°''il'f""0'51'< ,nown ,,, ,,)
''
c,coc,c°'~OcO---c,c,-,-,~~;,
,h,11
cump;cte """ dei,ver the"Monthly WIp lcack,,,g
of - 'ISample Report
,□""" L•Jan Coosol,d,,t,on r,yoff Report"
\ce Attachme,H SSample WIe (u,,sol,Oat,oa eapllTcack,nt Re;o,t lol,o

k,w.-,n <>>2p2 ,eµort, '
rho <Otvl<er shall complete •"d ddoer the monthly mtemal ,,·>to," IS,mplc monthl1
70!GS.00
o»anc,ng roconc,lea11on of o;, ect Cun,ol,datlon Payoff ~ct,v,tv from and to CO't1pletec
I
, ,he ,onsol,dalmg TIVAI 10:ertaco recon"l,al!On
i,:ncluding report fo,
See Atta<hm,,,t 7 Prn.eclu·e, to, 1,,,,,,,,1 System Sala,mna of
"""'I'
L
co·isol,C,at,nc nv ~, " """"" (00101,(l.,,,oa e,,·alf 1;~:~'~•o:•nl
lee At'" hm,,,e S L<a<nplc uf '"'""'' Sy•.,on-.Salaac,ai ,1 co,,,o ,O,tw'C

nv,~ ,,,,ertace -~"-'.,cl,o,c,o" s,vof! ""'·'"'
•vM shall reconcile con,ol,dal,ua fr"anml "'"'"V s,, -'ttad,·"cnt I
--
'7016".0U ,
;
1
'
70772 00 L'pon com olet,oe ot toe loan VO"f.c.tlon proce55 ac,d pdo, to lu"d"'' the
5emmo,y Statemon<
wnsc,l,">t,on >oan, conso;,datac shall ;end> to,n
!
I deta,l1ng the loaas lo be
w;th cc,ec letter ord ,nstcoct,oa, lo the l,ouowoc
rnasol,dated and ,1,l"g tl,o borrower 10 ,,,;,.,,
d,y, le ,o;pond with any I
/h•n~es or ,o,,cem,P"" lo loan Oemg bookoO. loo fitlachme"t JO
Samp ,' Lo.rn S"'" r0<1· Sla"emoat eom,s
i i
,------!-~~~----~~--------+---
1;1/'/ / Ul , ;,, Lua•,;,, """ \'.O:ur,•,,: ,1,,11c(H):l ,, tee 1 o;t, ,•,e~'"'" ,'""•'''
---+-----+-----
o·, i·:e '""''•"' sa,ro:e ,,t t,o """'" o,•n '"""'"'I st,:eme,·t 5<'L'
''
Att,ca,1 ,ent JO - '""'"le Lo,,, \on"""·, St,cem,,,,, fom» ! '
.
1
cn, c".· · -+-- ..-, -_-
..-,-.-,-,,-,
,-,
-.,,-
..-,, +-------+---------'-------
,c,c,,~,c,,,c,c,c,c,,c,c,-,c,-,-,-,c,c,
,c.c,,c,-.,c,-,,c,c,-. I
. , "'"''I, c "" ,,_moc,t ;;d,Jlt,r,•,ts w 'a so be oro•."Ced 10 1oe
,_.n:,: r., ccr c· ,-,, o,,, '"'"!Lee'"''; ,a,sfor 11·,cs D,sh,..,.,-n,•r:s
,re.,,,,,,, c ,·e,o: sa,o,:o,ecl Sr,,eac,h c'l See '""""''e"t ll
NFP, ,s hold" of ""d«lv,na loans tmoe , 0n,o:,d,;;;,1,c,.c,c"c,-,cw~oO~---j---------j---- ----1--------C
I'""" 00
occocdm,ly co al l,ans.ct,oos '<Quired to otf,ct pay-off of tltc undorly,oi
loaas -~':.!'"•~t,,,,,,,,,,,,s,; 0 ;~---
Comm,tmont
\tatomon1
I
PAGE 4 OF 8 ED-FSA-09-D-0014/0057
Attachment Page
Attachment A. Loan Consolidation Requirements
New Direct lo;m Consolidation Process Requirements

Req"irement # Reo""eme"\ commom, Comµlianl. Ye, er Nol Val1dat;oa Artifact
T ,•,soc. w ,o,i: o '"·' o,d 1,1,_,cr 10'1<\t·,e ,.,,,,.,,, Sec"'"'
S·,.ton O,I_,,c1, C Pcpor; sho•,_ 'C e•.•,decce o' 0,001.,1, S'/''°°'
,
l,1"" "S ,·.,ll· tee:, J.\S loaa coa;,I rlatocs a>, Lcac Pcoocam, fol
"·, "" ,u ·. '° ,,,,J ,cccwJ r,c,·, ,,,, 01•,As ,oan co11so o,w,
,_ """'" J;,col ,o,rcc,I -, •. rcocr; ,r,1 ,ncl,o, ,, data t ,:o,, ,no
'"'"'""''" ,,s, ,,,.,,., n , .. e ac<acl e,l ,,11n,.I, reocrc
1
·1 See ~t,,chmco\ 8 So,rolo So,v,cor lysteo, S., acc,ng """""I,. !Ion
7
'<epo,t 10,ev,o,sly know a as ,,.I
f,c0c,c,c,c,
c---l,c,-,-,,-,-,-"-,-,c,.c,c
00 1,-,-,,-,c,,c,-,
-"-0c0c,c,,-cec,c,,,c,c.c"c
0c,c.,,c
1c0CwC1ec,c,c,cec,c,,c,c,c,--f--------f--------" ------~
D,·ect Loa" Cor.sol1dat100 Payoff ~•po<t" .
1
See A\\achm,•nt b >,1mp e WI, Coo,nl,dat,no '°I"" '"'""' Repaci 1.,J,o

k"o'"' o, lol ,epo<t:
70lll 00 The"°'"(!' sii,11,omple,e and clel,ve, the mo,.lhly ,ntema! sy>tem Provide sample
:balam,ni mon"l,at,on of Olre<1 Coosol1dot1on Pa1•ottActlV"Vfrom ono to montl,ly completed I
ithe coosol1datia, TIVAS;ateITace
;,.,, a·:actini,•rr / "roced;re; fo, lrtem,,1 S;,l• I"'! e,,1.,ccin,: •al

I
ccn,ol do 1111, r IVASlnlc,•,«c Con;ol,doc,on Po,n<f ·"" ,it\
70/ll.00
lee t,ctc,,hm,•nl S E,a1n,1c o\ l.s<cmal >,·,Len ,,1,,,, "' of (O,><ol,Oa"n(

11VASlntedo<c' r o,TS0110.,,,onr,,dl ""'"'
70326 00 Dor,n, new LL Oevelopmecc cycle, ,ta""" spwfied '"the t11reHce, DMCS
I,hall p,o.iJe "' "'""'"""' of 'ead,r,e,s to tie;:10 Oe,elopmeat of aew lC
!,eqc,,emo,.t> Idec below du11ns Phase II o! ti,c 1molementa1,on See
f,ttachments 21 an.I CS
,mplementat,on 111,,el,aei, DMCS ,ha:I coal,noc ~oth ern,M3 proce»e> to 'Cor,pleted 1ST
,,,te,iace with lcg,c, OlC5 io,pavoff d ,ndecl,,na loam"'"'' p,;<J off E11olu,,.on Document
r-
tk,o,,n <onsol1dot,on lee A'1acn0'.ents 17 .,,,; ,S & Com•n,:mom
~· Ill•tement 1
o,nne Pl,o,e ll ol ,cnolcmcnla\,011 '"'""inc,

DMCS,hall modify or le,e,aie
Ute e<1>tino11mm anO/oc mtertace lo ac<epl LVC/<lVC<eqarn, by on• l,Comploted LST
11,n, b.1tch pcocrne, u111,,mestanda,d e(VC f,le ••vou1> to be prn.,ded E,aluat,on Ou,umenl
:See ,\t•,d,im11ts l, ',, lad 1' 1 , & Comm,tment
s,atement
10310 00 Du,m, Pha" II of 1mplementat;on t1n1el1ne, OMC5 shall mod,fy 01 leveca,e
tre e,,,t,n~ 5\'>:ern and/01 ,alertace to oc<ept pay-off mao1,e,t1 from
~IVAS by oo-1100 batch p,oces,e, clll,ing staada,d man;fes, file l>yout> to Coo,n11tment
be p,a,.Jcd. See mnclH''"" lO Statement
70331 00 DMCS shall acnmle aJjostcd o-,an1losts, or uploaO opprnpdately app,m·ed
,i,1,s rn on-lme bat,h pW«s, and sen cl lo the oni•oatlne TIVAS;, the
'.cam ot pa,-off amo,n: chJn,e,, omp•Y"'" ,ts.uaderpovmcnts See i
'" ,chment ,. -~~-~===~~=~~==~===+-------+--------·c"c'"c'c"~"c'c"'c''c'c'
f,coc,s,c,s,c,---{,c,",,",,",c,c,,~"
,;ol ,mplm,n1at,on ,;m,llne. DMCS ,h,I nwc,'y or Ceve»se --1
"''"'"' ,v,tem asd/ac 1a:ertace lo """P' cash-based 00\'0'ien<s IECT/ACHI
from ,MS/T,ea<u,y whi<h wdl ccq,,ce the ,otup/,,,e of REXauouM '""" sllats/s,mple
thrn,gn ACCand s•,eri;n, of ms sys Lem w,th /,e>;uf>/ to acces, payment liaoncial
,um1r.,y 1ofocmat1on See Att,camee,:< 1, 3, ••· and 12 ,epMs/rnmmltmont
l
70349 QO Dunn, •n,lial peno cC p,ocrn, PCA.,wdl
'"''"''"'
contlaue lo send ;II "Fa" T»t>" and "BIR' ooc.aios ,o the leg,cy lC
p,ocesse> with Dl("S to take adoan1age of the e">itlng ,nterta<e> and
"'"""'" w,lh NUS, Ooce DMC\ ,s bcoug~t ;p on the new CCpcoce,scs,
thea the new <lepl listed ,n the <equotements oolow w,11apply lee
Atta,hi,,ents 2, 2/ ,,nd 2' i
PAGE 5 OF 8 ED-FS,\·09·D·0014,0857
Attachment Page
Attachment A - Loan Consol1dotion Requirements
New Direct Loan Consolidation ProcessRequirements I

Rooui,ement ;t R•owement Comment> Co> i,ant - Yo, o, Nol Validation Anifart
70366 00
D"""' the lntlal µcnod al ,rnplementallo" -0! the ""' LCpro<eS>.
icon,olsdat1on loan .;ppl1eoC1oa,,nvolvmi any uadedy,n, luans held b\'
DMCS will be procossd o, <he •e~,cy IC p1oms thmueh DLCS.
(Comol,da<oon "PPIICatlOas ,svolv,ng no undeciy1n;: loan> helHnew
oppl,cat,o,,s will be procemd th•~u~h the new cC prnces, via
Stude"tloans,io, J ocl the TIVASas cos1nl1datms At that pomt, □ LCSwdl
i'"""""' to woe'. any appl,cat,oas ol,eady 1n p•oireis 11e \VIP) lee
- - --~--
7U387 OU
10tlaichs,en:s 1. 2, 27. acd lo
ji,,("s~h;II detecm,ne if the boHuwe," Ollem•,l,ng lo ,u11,ol,d>te any
1ur,derly1ni loan, t.,at ace held Dy DMC5 and, ,I not, ,de, toe bo"o-,o, to
the new LC prnms .,1 5tudoatlaans gov (tho, altema•.e pa<h app,oach w,11
t,e "' place anti I such time a, DMCI 15bco,sh< uo on the new LCpro,rncsl '
Sec Alta<hn,nis 1, 1, 1 I, o,,c 18
'1o_;~a.oo FMS ,hail make moOlkatinns <o ,,·stem process, file layout<, and
1n;<<u<l10,,sas op;,up,.ate to '"~mmodate new t,ansac<,onal proce<lel
i
,c;ult;ni (,om tu, o Consol10at1on pro,rne,. See Mtachment "
i i
PAGE 6 or 8 ED-FS/l,-09-0-0J1 4:'0C57
Attachment Page
Attachment B - Loan Consolidation Common Pricing
-·
Description Price
-- ---
·-----·-
Monthly Rate, Per Consolidation Completed Sl(b)(4)
I
One-Time Development Cost* Not-to-Exceed $1,200,000:
---- -- ----
"Developmenr costs for Loan Consolidation will be reimbursed for the actual costs
incurred, but not-to-exceed $1,200,000, for the first year only.
PAGE 7 0" 8 f:D-FSA O~-D-UC14/)057
---------
SCHEDULE Continued 7
SUPPLIES.'SERVICES I QUANTITY UNIT U~IT PHICS S AMOUNT S
Contracting Officec· Soo Kang. 202-377-3798,

sco kang@eC gov
, Pririary Contracting Officer Representative· Tammy

Con:relly, 202 377 3298 lammy.con11elly@ed.gov
A:tcrnatc Contract;ng Officer Representative(s):

Ly1n Smith. 20?-377-:1577, 1yn1um1th@cd.gov
?alr·c2 Wa~hington (2021 377-3845
Patrice. \/Vas·nIngto.1@ed.gov
IPr mary Technical Point of Contact· None
Alternate Technical Point of Contact(s).

None
I
L __
PAGE 8 OF 8 ED-f-S1\ C9 D-0014/0057

I 1 Contract ID Code 'rge,of Paaes I
2. AMENDMENT MODIFICATION NO. 13. EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO.

I 5
1
PROJECT NO. (if applicable)
I •
'
0058 AUG 20, 2013
6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE
Uni:ed States Oepar,m(ml of Educa:,on
Federal Stu:Jenl Aid/Mission Support Group See Block 6
Washington DC 20202
I 8. NAME AND ADDRESS OF CONTRACTOR {NO., Street. Country, State and ZIP Code} 9A. AMENDMENT OF SOLICITATION NO.
(x)
-
Cage Code: 41 UK7
1OA. MODIFICATION OF CONTRACT/ORDER NO.

rn.esA-C9·D•Oo1.:
X
'
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS I
D The above numbered solicitation is amended as set forth in item 14. The hour and date specified for receipt of offers D
is extended, Dis not extended. I
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of the following methods.
(a} By completing items 8 and 15, and returning copies of amendment: (b) By acknowledging receipt of this amendment on each copy of the offer submitted;
or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers FAILURE OF YOUR ACKNOWLEDGMENT TO BE
telenram or letter makes reference to the solicitation and this amendment. and is received "rior to the o"enin" hour and date soecified.
Check One A THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
X office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
D. OTHER (Specify type of modification and authority} I
E. IMPORTANT: Contractor r5<is not, I is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicilationlconlract subject malter where feasible)
a. The purpose of this modification is to incorporate the following Change Requests that were funded by Modification 0040 to Contract #ED-FSA-
09-D-0014: See Attachment.
... See Continuation Page
Except as provide~ heroin, all terms ar.d condil1ons of the document reforence<:Jin ,:em 9A or 10A, as r.erntofore ch,in~ed, remains urchange<J and In full force ~nd effect.
15A. NAME AND TITLE OF SIGNER (Type or print) 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
Sao Kang
202-377-3798 soo.kang@ed.gov
I 15B. CONTRACTOR/OFFER,cO~R~--- ___ _ 15C. DATE SIGNED, 16B. UNITED STATES OF AMERICA 16C. DATE SIGNED
b)(6)
AUG 20. 2013
I (Sigcat"ce Pf pecsocaathcci,ed IP sigc) (Si na re of Contra 111 fficer

>JSN 7540-01-152-8070 STA.'\DARD FOR\130. (Re'". 10-83)
l'rcl'iow, Edition unu.,ublc Prescribed b) GSA FAR (·18 CTR) 53.243
Continuation Page
b. The total value of the Change Requests (CR) identified in the attachment decreases the total amount
funded by Modification 0040 to Contract #ED-FSA-09-D-0014 by $246.900 from the previous modification
value of $183,858,188.10 to the new total $183,611,288.10
c. $183,611,288.10 remains available to fund additional change requests after incorporation of these change
requests.
d. All other terms and conditions remain unchanged and in full force and effect.

PAGE FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
OF 4 ED-FSA-09-D-0014/0058
Attachment Page
Changi.: Request The purpose of this Amount S246,900

#1744 Change Request is to
nllow borrowers to
submit Income
Based Repayment
(IBR) applications
via
St11dcntLuans.gov
and when possible
retrieve income
information for the
;:ipplication through
the data retrieval
tool from the (!RS
PAGE 3 OF 4 ED-FSA-09-D-0014/0058
SCHEDULE Continued
ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE $ AMOUNT $

soo.kang@ed.gov

Connelly, 202.377.3298, tammy.connelly@ed gov

Lynn Smith, 202-377-3577, lynn.smith@ed.gov

None
OBTAINED BY STUDENT BORROWER PROTECTION CENTERPAGE

AND AMERICAN FEDERATION
4 OF 4 ED-FSA-09 OF58TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
-D-0014/00
:
' AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT
'
I' Coctcac<IDCode
~e
t I 3
ofPaaes
: 2 AMENDMENT MODIFICATION NO I 3, EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ NO. 15 PROJECT NO. (ii applicable)
i
! 0059 i AUG23,2013
I 6. ISSUED BY CODE FSA-FS2 7. ADMINISTERED BY (If other than item 6) CODE .
Umle<fSta\es Cleoartment of Ec!ucatoon
Feder a.I Studee! Aid/Mission SuppM Group See Block 6
Washington DC 20202 ''
Soo Kang 202-377-3796 soo kang@ed gov
' !
8. NAME AND ADDRESS OF CONTRACTOR (NO, Street, Country, State and ZIP Code! 9A. AMENDMENT OF SOLICITATION NO.
HIGHER EDUCATION ASSISlANCE AGENCY PENNSYLVANIA DUNS· 007368103
1,1
~ :
1200 NORTH 7TH STREET Cage Code 41 UK7 i
HARRISBURG P4 171021444 98. DATED (SEE ITEM 11)
!
rn-FSA-09-D-0014
I X
! 108. DATED (SEE ITE'.M13)
CODE 0003077 4
·-1--~AGILITY CODE JUN 17, 2009
D The above numbered solicitation Is amended as set forth In item 14.The hour and dale spec1lied 1or receipt of otters D Is extended, D,s not extended.
Offers must acknowledge rece·pt of this amendment prior to the hour and date specified in the solic,tation or as amended. by one of the following methods;
(a) By completing items 8 and 15, and returning __ copies of amendment; (b) By acknowledging rec:eipt of this amendment on each copy of the offer submilled;
or (c) By separate letter or telegram which includes a reference lo the sol1citat1onand amendment numbers. FAILURE OF YOUR ACKNO\IVLEDGMENT TO BE
YOUR OFFER. If by vinue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each
telegram or tetter maKes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.
12 ACCOUNTING AND APPROPRIATION DATA (If required) Mod1ficatIon Amount· $0.00
Modification Obligated Amount $0 00
See Schedule
Check One i A THIS CHANGE ORDER IS ISSUED PURSUANT TO· (Spec,fy authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT ORDER NO IN ITEM 10A.
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANG:CS {such as changes In paying
office, appropriation date. etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
X Mutual agreement between ::Oothparties
D OTHER (Specify type of modification and authority}
E IMPORTANT' Contractor I is not, IX is required to sign this document and return copies to ihe issuing office.
1J, DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including sol1citat1on/contract subject matter where feasible)
The purpose of this modification is to incorporate the Fair Opportunity Process clause into coniract ED-FSA-09-0-0014 See attachment page.
Ail other terms and condit101s remain unchanged.
Except as provided here,n. all rem1sand cor,d,t,onsor the document refereoced in ,1err.9Aor 10A, es heretoforechanged, rema,ns unchanged and ,n fu',irorce and effecl
,..1,5'\NJE AND TITLE Of-SIGNER (Type or ,:,rint) 16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or pnnt)
,.'(r--·._nE1.iC
D~:!?£:.D·~- Soo Kang
202-377-3798 soo.kang@ed gov
;
i
'\I'--... ,;--...,
y'--;--V?"n7;(\/,:
- -, .
--'i.:1,•~-:-,.-,¾:· '11':('i/"'\
s,. , .:r-\;,,-· 'r1•
'~<.... I•,.,,,-,," ' •.' , -;-! " ., l, c, i
t5 ATE~t~NED 16B.UNITED STATES oF AMERfCA 16C. DA TE SIGNED
0
I
(b)(6) b)(6)
.J· ",·i/i
AUG 28, 2013
'I
,
(Signature al person authorized to sign)
I (S1cmature-'0fContractjna Officer) i
. '
NSN 7)40-01-152-80,0 STANDARD FORM 30. (Rev. 10-83)
Previous F.U,uo~unusable Prescribed by CJS,\ FAR (48 CFR) 53.243
AttachmentPage
FAIR OPPORTUNITY PROCESS
(a) In accordance with the Federal AcquIsit1on Streamlming Act (FASA) and FAR Part
16.S0S(b) Orderunder multiple-awardcomracts, the Contracting Officer will provide all
awardees a "lair opportunity" to be considered for each order in excess of $3,000.
(b) In general. the award of task orders will be made based on cost/price and/or other unrque
factors designated /or each task order. The Contracting Officer may tailor the selection
process for a specific task order to reflect the requirements and environment 01 the
proposed task order.
{c) As determined by the Contracting Officer, a contractor may not be given the opportunity for
consideration if -
(1) The agency need for such services is so urgent that provIdIng a fair opportunity
would result in unacceptable delays.
(2) Only one awardee is capable of providing the services required at the level of quality
required because the services ordered arc unique or highly specialized.
(3) The order must be issued on a sole-source basis m the interest ol economy and
efficiency because it is a logical follow-on to a task order already issued under this
contract, provided that all awardees were given fair opportunity to be considered for
the original order.
(4) It is necessary to place an order to satisfy a minimum guarantee.
(5) It Is known that a contractor has an unacceptable conflict of interest.
(d) In accordance with FAR Part 16.505(b)(2}, when an exception to the fair opportunity
exists, the Contracting Officer shall document the basis for using an exception to
the lair opportunity process.
(e) Notwithstanding the above provisions, as stated in the 1998 Amendments to the Higher
Education Act of 1965, P.L. 105-244, Federal Student Aid Is designated a Performance-
Based OrganIzatIon (PBO} and as such, the Federal Student Aid Contracting Officer may
use P L. 105-244 as authority in awarding task orders for the procurement of products or
services required by Federal Student Aid. Only Federal Student Aid shall use this authority.
PAGE 2 Qic 3 ED-ICSA-09-D-0014/0059
SCHEDULE Continued
! ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE $ AMOUNT $
Contracting Officer: Soo Kang, 202-377-3798.

soo.kang@ed.gov
Primary Contracting Officer Representative· Tammy

Connel,y, 202.377.3298, tammy.connelly@ed.gov
Alternate Contracting Officer Represemative(s):

Lynn Smith, 202-377-3577, lynn.smith@ed.gov
Patrice.Washing:on@ed.gov

None
I
PAGE 3 OF 3 ED-FSA-09-D-0014/0059
I
11-Contrad ID Code f''a_ge
ofl·'ages _1
1
' 1 i 2
2 AMEN'.)MENT MODIFICATION NO 3. EFFECTIVE DATE 4 REQUISITION/PURCHASE RfQ '-10 PROJECT NO. (1fapol,cableJ
I,
0060 SEP 10, 2013
6 ISSUCD GY CODE FSA-FS2 7 /1DMINISTERED BY (If other than item 6) CODE
Un1tEdStales [,epartrnent o! Educ,,t,on
FMe,~I S:uCenl ,\,~:Mission Suapo~ Group See Block 6
83C Fir~l St 'JE · Suit~ 9ff3
"Nasn,ngwn JC 20202
- ----
8 NAMf: AN!l ADDRESS OF COl~TRACTO;,_ (NO Street. Country, State and ZIP Code) 9A AMl:NDM[NT OF SOLICITATION NO
HIGHF:R EDUCATIO/\J ASSIST/,NCEAGENCY, PENNSYLVANIA DUNS 007368103 1,1
---
1200 NORTH 7TH STREET Cage Code· 4"UK7
~INANCIAL lc'ANAGEMENT 5Ttl FLOOR !
7ARF<ISBUr<G t'A 171021444 9B lJATED1SEE:.!TEM11)
i
I 10A. MODIFICATION OF CONTRACT/ORDER NO !
CD-F"A-C9-0-00:
4
'
X
-
10B. DAl ED (SEE I, El·,·I13)
CODE 0::J030774 FACILITY CODE JUN 17. 20D9
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF S9b!9,TcA;;TclO,N,s~---
0 The above numbered sol1c1\at1onrs amended as set forth in item 14. The ho'-'r and date speciNed fo, receipt of offms D
is extended. D
Is 1ct ex1ended
Offers m~st ~cknowledge receipt of this amendment pr,or to t:-ie hour and date specified in the solic1tat1onor as amendeo, by one of the following 'llethods:
(a) By complct,ng ,terns 8 and 15, and returning --~ cop,os o:amendment: (bl By acknowledging receipt of this amendment on each copy of the offer submitted.
or (c) ay sepMate letter or telegra77 which includes a reference to the sol1citat1onand amendrnent numbers. FAIL URE OF YOUR ACKNOVVI.E':DGMENTTO BE
YOJR o;cFER If by virtue of this on1enc!me11t your desire to change 2n offer already submitted. such change may be made by telegram or letter, provided each
lele, ram or le,tter makes rlc!fernnce,to the sol1r.,tal1onand th,s amendrr,ent, and is received nor to tho o c;~n0g0c0c0o0, 0a0cc~da
0,,e,s0pe0 c0;fi;;,eod~----~~~~~-
12 ACCOUt\ TING AND APPROPRIATION DATA i'lf required) Modification Amount S-221 798 73
Modification Obligated Amount S-221 798.73
See Schedule
Check One 1\ THIS CHANGE ORDER ,S ISSl.;ED PURSUAt\-;- TO (Soec1fy authority) THC CHANGES SC:T r=QiHH IN ITE:M 14 ARE MADE iN THE
-------, CONTRAC1 iJRIJE::fSNC iN 11cM. 0/l,
B TH[ ABOV[ NUMC)f'RF:D CONTRACTIORDEcR IS MODIFIED TO RffLECT 'HE ADMINISTRATIVE CHANGES isuch as clianges In paying
office, apprc,pnation dato. etc) SET ~ORT!-<.IN lfEM 14. PURSUANT TO THE AUTHORITY OF FAR 43.103(b)
C THIS SUPf'LEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF
E IMPORTANT· Contractor I Is not, Ix 1srequired to sign this document and return copies to the issuing office
14 Df::SCRlf-' I ION Of- AME::NlJMCNi'/MOOlf- ICATION (Organized by UCF section headings, 1ncludmgsol1c1tat1on/contractsubject matter where feasible)
The purpose of this mod1ficat1c n 1sto de-obl:gate excess funds In the amount of $221 798 73. from Contract Number ED-FSA-09-0-0014, Line
liem 0025 The tota! contract 11alue is decreased by $?.2179873 from S~93,224,240 34 to $193,002,441 61
All othe~ terms and conditions :er1aIn unchanged.
E,cept as p,o,,cc,J here111all 1e,rns ard rnna,,,0"s of l"e ccclltnent referenred,n ,1e,n9A or 10A as hor~tofo•~ "haoge<1 rema,ns unchansed and In foll force and ettecl
. \5A_-NAME_,~NDT_l;°lE,9:"·~l_qNE;R fType or print) 16A NAME AND TITLE OF COWR,;CTING OFFICER (Type or orint)
".'.,.f··",,;,•_;·----
't..)·-y.~.-_J···- , 1.,-, ;~i!l)7~~J~h16 angm.smrth@ecigov
\.-, / ~:/~~-:~;;~J~~~,~~'
h.s¥2~t-+'J;~-~;J;1i·1:·:~·~~'0C::•;,
/_~:•(:-\,-'-
-\t{-r··'i ~~·t:- UNITED STATC:S OF AMERICt-, - -
f- -- ------;;'" . >
b)(6)
! l(b)(6)
SEP 112013
I ,:Signat~re of person authon,ed lo srgn) i

I
N',~ 7_,--10-01-1)2-8()7{, :-.I A'\l)ARI) ~OHl\l 30. (Re, JO-S3J
l'r~, 1n11, j .d11:ur,unusc1hl~ l'r~scrib~d by (JS.,\ !'AR (48 CFR,1 53.2-B
"-··· ·-·--· -- . - ---·-- - -------------

i SCHEDULE Continued
' ITEM NO SUPPLIES,'SERVICES OUA>JTJTY UNIT UNIT PRICE $ AMOUNT S
' !
;
Contractmg Offi:::er: Angie Smith, 202-377-4016,
eng1e smith@ed.gov !
Primary Ccntract·ng Officer Representative: Tammy

Conneily, 202.377.3298, tammy conneliy@ed.gov
A'ternate Contraciing Officer Represental1ve(s):

;
Lynn Smith, 202-377-3577, lynn.smith@ed.gov '
Patnce \11/ash,ngton, (202) 377-3845, !
Patrice.Washinglon@ed.gov I
i !
Primary Technical ?oint of Contact None
A!temate T echr.1cal Point of Contact(s):

None
!(Changed Line Item)

1Pennsylvania Higher Education Assistance Agency to '
0025 1.00, SE 6,978,201 27 6.978,201 27
orovIce servicing operations.
(De-Obligation of Excess Funds - $221,798.73)
''
Accou11tI11rand Appropriation Data:
0202A2012.8.2012. ENB00000.6CA.2521 A.AB5.000.
0G00.0000:J0
S5.978.20' .27
i
:
~- --~---------------~--~----_J'----~
PACE 2 OF 2 EO-FSA-09-0-0014/0060

1 Contract ID Code
,-
i
;
Page of Pa~
1"141
j
2 AME:NDMENT MODI FICA l lOK NO. 13.EFFECTIVE DATE:. I 4 REQUISll I0N/PU"\CHASE REQ. NO 15.PROJECT NO (111ppl1cable)
' 0061 SEP 20, 2013 '';

6. ISSUC:O BY CODE FSA-FS2 7, Arn✓ INISTERED BY (If other than item G) CODE
U·11tedS:atcs Department of Eocca:,~n
Federa1 S:ucen; i\1J1M,ss1on Support Group See Block 6
030 F•rs: St NE - Suite 91F3
'Nasn111glan DC 20202
---·------
B NAME ANO ADDRESS OF CONTRACTOR (NC, Str€e°Ccountry,State and ZIP Code) 9A AMENDMENT OF $6L1CITA'r1C.'J NO.
HIGHER [CUCATI0N ASSISTAl'sCE AGENCY. PENNSYLVANIA DUNS· 007368103 (X}
~
120J NORTH 7TH STREET Cage Code· 41UK7
FINANC,;\L M,'l,\JAGFMENT 5TH f!...00"/
10A. M0DIFICAl ION OF CONTRACT/ORDER NO.

' cci-,sA-O\ c.0014
'
' X
-·"'
ms DP.TED (SEE ITEM 13)
CODE 0003077 4 7 FACILITY CODE JUN 17, 2009
~--------------~1o1c•c"c'sSoffsS~M ONLY APPLIES TO AMENDMENTS OF S0LICITATIO=N 0S ______________ ~
I D The above numb(Hed sol1c1tat10:1is amended as set forth In ,tern 14 The hour and dale specified for receipt of offers D ;s extended O1s not extended
I Offers mu,;\ acknow'edge receipt of this amendment pnor to t11ehour and date specified In the sol1citat1onor as amended, by one of the following methods
I (a) Ry con1plet1ng items 8 and 15, a1d returning ___ copies of amendment. (b) By acknowledging receip1 of this amendment on each copy of the offer submitted:
l
or (c) By separate letter or telegram which includes a reference to the solic1ta1ion and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
Rt:CEIVE=i AT THE PLACE DESIGNATED ~OR THC RECEIPT OR OFFERS PRIOR TO THE HOL'R ANO DATE Sl'ECIF 1E0 MAY RESULT IN RE'JECTION OF
YOUR OFFl::R If by viriue of lbs amendment your desire to change an offer already subm1tIed, such change may be made by te'egram or ietter, prowjed each
:elegram or lelter mai<es reference tQ_]'.1_i,__s_oli:::itat~on
and lh1s amendment. and Is received prior to \he opening hour a~C date spec,fied
I 12. ACCOUNTING AND APPRDPRIA TI0N DATA (If required) Mcd1ficat1or, Amount· SO00
I See Schedule Mod1f1cat1or, Obligated Amount: SODO
13. THIS ITEM ONLY APPLIES TO MODIFICAl"I0N OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
Check On~ A. THIS CHANCE ORDER IS ISSUED PURSUANT TO (Specify authorjty) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE
CONTRACT :JRDE"l NO IN ITEM 10A.
B Tf,E ABOVC: NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES {such as ct-anges In paying~
office, appropriation date. otc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43 103(b)
- ·1' ·c:.--T111s
SCJDPLEMENTt-L AGREEMEN I IS ENTERED INTO PURSUANT TO AUTHORITY OF
E IMPORTANT Cont:ac:or is not, Ix :s required to sign this document and !~.!__u~- copies to the issuing office
·,4 '.:ltSCRIPTION OF AMENDMENl
~--~~~---
IM0DIFICA TI0N (Orga111led by UCF section headings, ,ncIudIng sol,c1la\lonlcontract subJeCt matter where feasible)
The purpose oi !his modIficat1on Is to replace the loan ConsolIdatIon Requirements, added per Modification 0057 with Attachment A• Loan
Consol1dat1on Requirements. Re,1Ised
All other terms and condItIons rema1r1 unchanged
SEP 24: 2013
I (S1griature of Contrac\ing Officer)

\J .~\J 7 5.1().()] • l 52 ·8071) ST.\"ID.-\RO FOR~! 30. (Re,. 10-83)
l',niuL.s l.Jt'.J<Hl urn1,:,h]~ l'rcscnbctl b) GS/I FAR (,1~ CFf{J 53.243
Attachment Page
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PAGE 2 OF 41 ED·FSA-09-D-0014/0061
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Attachment A. Loan Con«>lldatlon Requlroments. Re,i,ed
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PAGE 3 OF 41 ED-FSA-09-0-0014/0061
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PAGE 4 OF 41 ED-FSA-09-0-001410061
Attachment Page
Atta<Omont A• loan Coa,olidatlon Roq"i«mear, - ~evl,ed
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PAGE 5 OF 41 ED-FSA-09-D-0014/0061
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PAGE 10 OF 41 ED-FSA-09-D-0014/0061
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PAGE 11 OF 41 ED-FSA-09-0-0014/0061
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Attachment A - Loan Con,olidatloo R•qwhement,. Rov;,.d
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PAGE 12 OF 41 ED-FSA-09-D-0014/0061
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PAGE 13 OF 41 ED-FSA-09-D-0014/0061
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PAGE 15 OF 41 ED-FSA-09"0-0014/0061
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PAGE 21 OF 41 EO-FSA-09-D-001410061
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PAGE 22 OF 41 ED-FSA-09·D-0014/0061
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PAGE 24 OF 41 ED-FSA-09-0-0014/0061
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PAGE 27 OF 41 ED-FSA-09-D-0014/0061
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PAGE 33 OF 41 ED-FSA-09"0-001410061

FOIA Production US Department of Education On PSLF - Pt. 2

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OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT

SECTION7: WHERETO SENDTHE COMPLETEDFORM

U.S.Department of Education Domestic 855- 265-4038

SECTION8: IMPORTANT INFORMATION ABOUT PSLF

PHe.aa Employment Certification Review Manual

SECTION 8: IMPORTANT INFORMATION ABOUT PSLF (CONTINUED)

PHeaa Employment Certification Review Manual

SECTION 9: IMPORTANT NOTICES

Employment Certification Review Manual

PHe.aa Employment Certification Review Manual

Fedloan ServicingProcessorUpdate - PSECF ProcessingUpdate

From CS Operational Communications/Fedloan Servicing

Effective immediately, if an ECF is received for an American Civil Liberties Union

PSECF for EIN 20-8091013 - 11.08.2016

The employers associated with EIN 20-8091013 are:

PSLF ECFProcessor Reminder (Resource Updates 10.14.16)

If the employer is located in the database:

If the employer is not located in the database:

PSLF Reminders - 11.03.2015

• Employment Certification Form (ECF)

There are a few common misconceptionswhen it comes to PublicService Loan

MISCONCEPTION: Borrowers should wait to submit an ECF confirming their

advise a borrowerto wait on submittingan ECF. Always encourage them to submit an

MISCONCEPTION: Employment as a congressional staffer does NOT qualify for PSLF.

PSLF TRUTH: Employment as an elected member of the U.S. Congress (Senator or

Exception: If a congressional staffer is working for a political campaign (considered a

Top 3 PSLF Reminders (Resource Updates 06.14.17)

1. On PSLF Payment Tracker Letters

For more information, see the following articles in KC:

Public Service Loan

Table of Contents .................................................................................................... 1

PSLF ECF Processing Procedures

Document Version Control

1.0 Existing BU 1/04/2013

2.2 Modifications to numbering/lettering in Section 1.8, S. Dalbor 3/03/2016

2.3 Compliance approved version K. Myers 3/08/2016

f loan PSLF ECF Processing Procedures

Compliance Approved K. Myers 8/1S/2016

f loan PSLF ECF Processing Procedures

BMF Business Master File

DCN Document Control Number

DOE Department of Education

ECF Employment Certification Form

EIN Employer Identification Number

FLS Fed Loan Servicing

FSA Federal Student Aid

IBR Income-Based Repayment

ICR Income-Contingent Repayment

IRS Internal Revenue Service

NSLDS National Student Loan Data System

0MB Office of Management and Budget

PAYE Pay As You Earn

PSECF Public Service Employer Certification Form

PSLF Public Service Loan Forgiveness

SSN Social Security Number

TLF Teacher Loan Forgiveness

f loan PSLF ECF Processing Procedures

• Federal Direct Stafford/Ford Loans (Direct Subsidized Loans)

f loan PSLF ECF Processing Procedures

Action Request Code: PSECF

f loan PSLF ECF Processing Procedures

Section 1: Employment Certification Form {ECF) Process

Doc Comme-nt: _,:-~; ·a Errc-

* - - **** DOB: MM/DD/YYYY